Legal

Cookie Policy

Stratosphere Advisors LLC

Cookies Policy

This Cookies Policy sets out the basis on which we, Stratosphere Advisors LLC, use cookies and similar technologies on or in relation to our website www.stratosphere-advisors.com .

This Cookies Policy is effective from 23rd August 2018. 

‘Essential’ cookies are automatically placed on your computer or device when you access our website or take certain actions on our website. Non-essential’ cookies and other technologies are only placed on your computer or device if you have consented to us doing so. For information on the difference between essential and non-essential cookies.

For information on how you consent and how you can withdraw your consent to us placing non-essential cookies and other technologies on your computer or device, see the section below entitled How to accept or reject cookies.

About cookies

What are cookies?

Cookies are small data files sent by a website’s server to a web browser, processor memory or hard drive and stored there. They can be used for a range of different purposes, such as customizing a website for a particular user, helping a user navigate a website, improving that user’s website experience, and storing that user’s preferences and login information.

Essential and non-essential cookies

Cookies can be classified as either ‘essential’ or ‘non-essential’.

Essential cookies: these are cookies that are either:

  • used solely to carry out or facilitate the transmission of communications over a network; or
  • strictly necessary to provide an online service (e.g. our website or a service on our website) which you have requested.

Non-essential cookies: these are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (‘analytical’ cookies) or cookies used to display advertisements to you (‘advertising’ cookies).

Session and persistent cookies

Cookies can be classified as either ‘session’ or ‘persistent’, depending on how long they last after they are placed on your browser.

Session cookies: session cookies last for as long as you keep your browser open. They expire when you close your browser.

Persistent cookies: persistent cookies expire at a fixed point in time or if you manually delete them from your browser, whichever occurs first.

First and third party cookies

Cookies can be classified as ‘first party’ or ‘third party’.

First party cookies: these are cookies placed on your device by our website domain.

Third party cookies: these are cookies placed on your device by third party website domains.

If you require further information about cookies in general, please visit www.allaboutcookies.org

We have categorized the cookies we use in four categories

COOKIE PURPOSE
ESSENTIAL COOKIES

(STRICTLY NECESSARY)

Used solely to carry out or facilitate the transmission of communications over a network; or

strictly necessary to provide an online service (e.g. our website or a service on our website) which you have

requested.PREFERENCE & FUNCTIONALITY COOKIES

These cookies collect information about your choices and preferences and make using the website more practical

They are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

ANALYTICS & CUSTOMIZATION COOKIESThese cookies collect information that is used either in aggregate form to help us understand how our websites

are being used to help us improve our websites and application for you in order to enhance your experience.ADVERTSING (TARGETING) COOKIESThese cookies are used to make advertising messages more relevant to you and your interests. They also

perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly

displayed, and in some cases selecting advertisements that are based on your interests.

List of Cookies Used

Name of Cookie Essential or Non-essential? Type of cookie First or Third party? Session or Persistent? Expiry Time Purpose
PHPSESSID Essential Essential First Session Session Opening users session
NID Non Essential Preference Third Persistent Month Remembering Google user preferences
_ga  Non Essential Analytics Third Persistent 2 years Google Analytics: distinguishes between users

Managing Cookies

 

How to opt out of essential cookies

Most browsers allow you to block all cookies, including essential cookies. Please note, however, that if you block all cookies, parts of our website and its functionality may not work or display properly.

You can delete existing cookies from your browser by clearing your browsing data and ensuring that the option to delete cookies is selected.

More information

Google Analytics cookies are classified as first party cookies as they are set by our website domain, although Google collects and processes information from our use of Google Analytics. To find out more about how Google handles information collected from Google Analytics, see Google Analytics’ privacy policy, which is available here: https://support.google.com/analytics/answer/6004245

For information on how Google uses data from cookies it uses, please visit www.google.com/policies/privacy/partners/

How to opt in or out from analytical cookies

See the section below entitled How to accept or reject cookies

To opt out of Google Analytics tracking across all websites in general, you can do so here: http://tools.google.com/dlpage/gaoptout

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

Terms of Use Policy

STRATOSPHERE ADVISORS LLC
TERMS OF USE

Updated: 23RD August 2018

General Description

The website of Stratosphere Advisors LLC (“SALLC”) is made of all sections and subsections hosted on “stratosphere-advisors.com” (the “Website”).

By accessing the Website and the material and information contained herein, you acknowledge that you have read, understood, accepted and agreed to be bound by the following terms and conditions.

Disclaimer

Please read these Terms and Conditions before using the Website. By using the Website, you acknowledge that you have accepted these Terms and Conditions. If you do not accept these Terms and Conditions, do not use the Website.

SALLC has used its best endeavors to make sure that all the information, data and other material (copy and images) on the Website are accurate and complete. The content and opinions of author(s) expressed in publications are the sole responsibility of the author(s), and do not engage SALLC as an institution. SALLC does not accept liability for any errors or omissions.

The Website may contain links and references to third party websites. These are provided for your information only. SALLC accepts no responsibility or liability arising from access to, or for the material on, any site to which it is linked. In addition, SALLC makes no warranty as to the accuracy and availability of content which are not under the stratosphere-advisors.com domain.

Use of the Website & Intellectual Property Rights

All texts, software, graphics, photographs, sounds, videos, information, interactive features and any other site content and arrangement are owned by SALLC or its licensors and are subject to copyright, trademark rights and other intellectual property rights.

SALLC authorizes you the view and download the materials on the Website for your personal, non-commercial use, provided that you retain all rights contained in the original materials on any copies of the materials. You are strictly prohibited to modify, reproduce or publicly display, perform, redistribute, use or transmit any information, data or other material contained in the Website for any public or commercial purpose unless you obtain prior written authorization of SALLC. As such, the use of the full-text of academic or other publications on the Website is subject to copyright law.

Material posted on the Website by third parties is copyrighted to those parties unless otherwise stated. If you breach any of these Terms, your authorization to use the Website automatically terminates and you will be held liable for all possible damages. In addition, you shall immediately destroy any downloaded or printed material.

No Liability and Indemnification

Neither SALLC nor any party involved in the creation, production or delivering of the content on the Website shall be liable for any claims or direct, indirect, incidental or consequential loss of any nature arising directly or indirectly from use of the information, data or other material on the Website, nor for any direct, indirect, incidental or consequential damage or any punitive damages arising out of or in connection to the use of the Website.

The Website is constantly being developed. SALLC used its best endeavors to ensure that the information contained on the Website was accurate at the time of creation or modification. Users shall notify SALLC of any errors or inaccuracies they may find while using the Website.

SALLC uses its best endeavors to ensure that its IT infrastructure is free from viruses but accepts no liability for damage caused by viruses acquired via the Website. Users browse at their own risk.

It is SALLC policy to respond to notices of infringement of third parties’ rights that comply with applicable laws by expeditiously removing unlawful content and terminating the account of repeat infringers.

Any user of the Website shall indemnify, defend and hold harmless SALLC, its partners, officers, directors, agents, affiliates, licensors and their suppliers from and against any claim or liability arising out of, or in connection with using the Website.

Spam & Address Grabbing

The automatic or manual collection of email addresses from the SALLC Website is strictly prohibited for any commercial use, including but not limited to resale or for the unsolicited sending of emails.

Modifications

SALLC may modify these Terms and Conditions at any time and such modifications shall be effective immediately upon posting of the modified terms. Please consult our Privacy Policy and Terms and Conditions systematically to ensure you are up to date with any of our practices concerning privacy and other important information.

Privacy Policy

Please consult our Privacy Policy to obtain more information on the protection of personal data and the use of cookies.

Applicable Law

These Terms and Conditions and the Privacy Policy shall all be governed and construed by the laws of the State of Delaware. You agree that any legal action or proceeding in connection to or arising out of the use of the Website between SALLC and the user shall be brought exclusively before the Courts of the State of Delaware.

Privacy Policy

Stratosphere Advisors LLC

Privacy policy

This Privacy Policy sets out how we, Stratosphere Advisors LLC (“SALLC”) collect, store and use information about you (the “User”) when you use or interact with our Website, www.stratosphere-advisors.com (the “Website”) and where we otherwise obtain or collect information about you.

Stratosphere Advisors LLC processes the personal data transmitted to it in accordance with the legislation in force, notably EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25th May 2018 (the General Data Protection Act or “GDPR”).

Access to the Website implies the User’s full and unreserved acceptance of this Privacy Policy, as well as SALLC’s general Terms of Use Policy and Cookies Policy.

This Policy describes the information we process to support the Website, newsletters, blog posts, events and other services and features offered by SALLC. You can find additional tools and information in our Terms of Use and Cookies policies. This Privacy Policy is effective from 23rd August 2018.

We believe you should always know what data we collect from you and how we use it, and that you should have meaningful control over both. We want to empower you to make the best decisions about the information that you share with us.

We require certain information to provide our services to you. For example, you must have an account in order to hold a profile on our Website. When you choose to share this information with us, we collect and use it to operate our services.

SALLC is committed to maintaining your confidence and trust with respect to your privacy.  Please read this privacy policy carefully to understand our practices about how we collect, use and share your personal information.

This Privacy Policy applies when you visit or use our Website and other Services, including events, that refer or link to this Privacy Policy (each, a “Service”).  This Policy may be supplemented by additional privacy statements, terms or notices provided to you. SALLC is the primary controller of your personal information provided to, or collected by or for, the Service.

Our details

The data controller in respect of our Website is Stratosphere Advisors LLC, 16192 Coastal Highway, Lewes, DE 19958 United States of America.

Stratosphere Advisors LLC is an independent public policy consultancy formed in the State of Delaware with Delaware State File Number 6350588.

If you have any questions about this Privacy Policy, please contact the data controller at info@stratosphere-advisors.com or by writing to

 

Stratosphere Advisors LLC
Attention: The Data Controller
16192 Coastal Highway
Lewes, DE 19958
USA

What kinds of information do we collect?

We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies.

Information you provide to us

The types of personal information that we collect directly from you depends on the content and features of the Service you use and how you otherwise interact with us and may include:

Contact details, such as your name, email address, postal address, phone number and social media handles;

Account login credentials, such as usernames and passwords, password hints and similar security information;

Other profile information from your account registration, including educational, professional and other background information, such as your current position, practice area and areas of interests and photo;

Content that you upload and share or store in your account, such as annotations, comments, contributions and replies;
Payment information, such as a credit or debit card number if supplied to SALLC to purchase a Service;
Information that you communicate to us, such as questions or information you send to SALLC;
Data that you provide to us as part of interacting with the Service, such as your favorites and search queries; and/or
Communications preferences, such as your preferred language and the frequency, type and format of the alerts you sign up to receive.

Data from your institution

We may obtain information about you from the institution with which you are employed or affiliated in order to activate and manage your access to and use of any institutional subscription to the Service, including:

Contact details, such as your name and institutional email address, postal address and phone number;

Other account registration information, such as job title; and/or
Institutional user ID.

Data from other sources

We also may obtain contact details and other information about you from third parties, including:

Social networks that you grant permission to the Service to access your data on one or more networks;

Service providers that help us determine a location in order to customize certain services to your location;

Partners with which we offer co-branded services or engage in joint marketing activities; and/or

Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

Device and usage data

The Service may automatically collect information about how you and your device interact with the Service, such as:

Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, unique device identifier and other technical identifiers, error reports and performance data;

Usage data, such as the features you used, the settings you selected, URL click stream data, including date and time stamp and referring and exit pages, and pages you visited on the Service;

For location-aware Services, the physical location of your device.

We may collect this data through our servers and the use of cookies and other technologies. You can control cookies through your browser’s settings and other tools. However, if you choose to block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Service. For more details, see the Cookies section below.

How do we use this information?

We use the data we collect from the above sources:

to administer our Website, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
as part of our efforts to keep our Website safe and secure.
We may use the data we collect to set up a user account.
We may also use the data you send to us via our Website and/or Services, to communicate with you via email and, possibly, other means, regarding events, publications, blogs and newsletters we think may be of interest to you. However, you will always be able to opt-out of such communications at any time (see How can you exercise your rights provided under the GDPR? section below).

We are committed to delivering a relevant and useful experience to you. Depending on how you interact with us and the Service, we use your personal information to:

provide, activate and manage your access to and use of the Service;
process and fulfill a request, order, download, subscription or other transaction;
offer you customized content and other personalization to make the Service more efficient for you and more relevant to your interests and geography;
enhance and improve the Service, such as add new content and features;
notify you about changes, updates and other announcements related to the Service;

deliver targeted advertisements, promotional messages, and other information related to the Service and to your interests;
provide technical, product and other support and help to keep the Service working, safe and secure; and/or

identify usage trends and develop data analysis, including for the purposes of research, audits, reporting and other business operations, such as to pay royalties and license fees to third-party content providers, determine the effectiveness of our promotional campaigns, evaluate our business performance, or in other ways pursuant to a customer agreement.

We may also use your personal information to:

Respond to your requests, enquiries, comments or concerns;
Conduct and administer user testing and surveys and promotional offers;
Provide you with relevant promotional messages and other information about products, events and services of ours, our partner organizations and third parties such as event partners and sponsors;

Enhance and improve our products, events and services and develop new ones; and/or
Comply with our legal obligations, resolve disputes and enforce our agreements.

How is this information shared?

We do not sell your Personal Data to anyone nor do we routinely share it with other organizations. However, there may be circumstances under which we may have to share your information as follows.

Your institution

If you access the Service through a subscription administered by your institution, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorized by your institution for the purposes of usage analysis, subscription management, and remediation. We may also disclose to your institution or other third parties non-personally identifiable information, such as anonymous usage data reports and aggregated information, subject to any applicable legal or contractual obligations.

Our partner organizations and service providers

Depending on the Service provided, we share your personal information with our:

Affiliates, sponsors and partners, and certain organizations that provide technology, customer service and other shared services functions; and/or
Suppliers and service providers, including editors, reviewers, payment processors, customer support, email service providers, event venues and service providers, mailing houses, shipping agents and IT service providers;

to process the information as necessary to provide the Service, complete a transaction or fulfill your request or otherwise on our behalf based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.

Web server log information

We use a third party server to host our Website, 1and1Internet.com, the privacy policy of which is available here

https://www.1and1.com/terms-gtc/fileadmin/Terms/PDF_US/2018_01_US_Privacy_Policy_DWE.pdf

Our Website server automatically logs the IP address you use to access our Website as well as other information about your visit such as:

  • The pages accessed
  • information requested
  • the date and time of the request
  • the source of your access to our Website (e.g. the Website or URL (link) which referred you to our Website)
  • your browser version and operating system

 

Our server is located in a data center in the United States of America.

Use of Website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and Website remain uncompromised. This includes analyzing log files to help identify and prevent unauthored access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow, any attempt to identify you from the information collected via server logs.

Use of Website server log information to analyze Website use and improve our Website

We use the information collected by our Website server logs to analyze how our Website users interact with our Website and its features. For example, we analyze the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our Website. For example, we use the information gathered to change the information, content and structure of our Website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our Website, including

  • essential
  • functional
  • analytical

For further information on how we use cookies, please see our cookies policy.

You can reject some or all of the cookies we use on or via our Website by changing your browser settings by using our cookie control tool but doing so can impair your ability to use our Website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties who process your information for us on our behalf. We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Google Analytics

Google collects information through our use of Google Analytics on our Website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information: Information collected by Google Analytics (your IP address and actions you take in relation to our Website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Your choices

As stated, we may share your personal information with our affiliates and sponsors, joint venture partners and other third parties, including entities for which we are acting as an agent, licensee, application host or publisher, that wish to send you information about their products and services that may be of interest to you as determined by your choices in managing your communications preferences and other settings. The Service may let you post and share personal information, comments, messages, materials and other content. Any such information that you disclose publicly or in discussion fora in the Service may be collected and used by others, may be indexed by search engines, and might not be able to be removed. Please be careful when disclosing personal information in these public areas.

Legal reasons

We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

meet any applicable law, regulation, legal process or other legal obligation; detect, investigate and help prevent security, fraud or technical issues; and/or protect the rights, property or safety of SALLC, our users, employees or others;

and as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company.

What is our legal basis for processing data?

When we collect, use and share from you any personal information within the scope of European data protection laws, we do so:

where necessary to provide the Service, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
where necessary for our compliance with applicable law or other legal obligation;
where necessary for the performance of a task carried out in the public interest;

where applicable, with your consent; and/or
as necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, or fulfill our other legitimate interests as described in the sections above, except where our interests are overridden by your privacy rights.

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

How can you exercise your rights provided under the GDPR?

Under the General Data Protection Regulation, you have the right to access, rectify, port and delete your data. You also have the right to object to and restrict certain processing of your data. This includes:

the right to object to our processing of your data for direct marketing, which you can exercise by using the “unsubscribe” link in such marketing communications, and the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right by contacting us by email at info@stratosphere-advisors.com

The Service may allow registered users to directly access their personal account information and make corrections or updates at any time.

Keeping such information up to date is solely the responsibility of the user. Registered users may also close their account directly through the Service or by contacting SALLC.

You have the right under European and certain other privacy and data protection laws, as may be applicable, to request free of charge:

Access to and correction and deletion of your personal information;
Restriction of our processing of your personal information, or to object to our processing; and/or Portability of your personal information.

We provide individuals with the opportunity to access, review, update, and delete any personal data we hold on them. You can send an email to the address above for this purpose. If you ask us to delete your data, we will do so. Please note that we may be required to retain and use your information if necessary to comply with legal obligations or to resolve disputes. We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.

You can customize and manage your communications preferences and other settings by emailing the address below or by using the “opt-in/out” or subscribe/unsubscribe mechanisms or other means provided within the communications that you receive from us or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

You can always opt not to disclose information to us, but keep in mind some data may be needed to register with us or to take advantage of some of our services.

For your convenience, hyperlinks may be posted on the Website that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Policy does not apply to the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect data in addition to that which we collect on the Website. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy policy of each Linked Site that you visit to understand how the data that is collected about you is used and protected.

Data retention, account deactivation and deletion

We retain your personal information for as long as necessary to provide the Service and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.

We retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

How do we respond to legal requests or prevent harm?

We may choose to access, preserve and share your information with regulators, law enforcement or others:

In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction and is consistent with internationally recognized standards.

When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorized use of the Service, breaches of our Terms or Policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Service), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Services.

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

 

Enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

 

Legal or potential legal disputes or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

 

Ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Information that we receive about you (including financial transaction data related to purchases made with SALLC) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation or investigations of possible breaches of our Terms or Policies, or otherwise to prevent harm. We also retain information from accounts disabled for term breaches for at least a year to prevent repeat abuse or other term breaches.

How do we operate and transfer data as part of our global services?

We share information globally, both internally within the SALLC infrastructure and externally with our partners. Information controlled by SALLC may be transferred or transmitted to, or stored and processed in other countries outside where you live for the purposes as described in this Policy. These data transfers are necessary to provide the services set forth in our Terms of Use, and to globally operate and provide our services to you. See our Terms of Use Policy [LINK] for further details.

Your personal information may therefore be stored and processed in your region or another country where SALLC and its service providers maintain servers and facilities.

We take steps, including through contracts, to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law. Where personal information is transferred from the European Economic Area (“EEA”) or Switzerland to a country that has not received an adequacy decision by the European Commission, we will rely on appropriate safeguards such as the European Commission-approved Standard Contractual Clauses and Privacy Shield Frameworks to transfer the data.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation. We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us. If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Children

We do not knowingly collect or solicit personal data from anyone under the age of 16. If you are under 16, please do not attempt to register or send any personal data about yourself to us. If we learn that we have collected personal data from a child under age 16, we will delete that data.

Data security

We safeguard your personal information against accidental loss, theft and misuse and unauthorized access, disclosure, alteration and destruction through the use of appropriate technical and organizational measures. These include:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
  • using secure servers to store your information
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software

Unfortunately, no company or service can guarantee complete security, unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user data at any time.

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our Website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

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+44 7767 418 957

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