Effective Date: May 18, 2018
Last Updated: August 6, 2019
Your continued use of the Site signifies consent to this Policy as may be amended from time to time.
Please read this Policy before using the Site or submitting any personal information. By using the Site, you are accepting the practices described in this Policy. The use of information collected through our services shall be limited to the purpose of providing the relocation services for which our clients (“Client”) have engaged Sterling Lexicon to provide. Note: the privacy practices set forth in this Policy are for this Site only. If you link to other websites, please review the privacy policies posted on those web sites.
The legal bases for collecting and processing your personal information are: a) your consent for the purposes listed in this Policy; b) you may be a potential customer who contracts with Suddath to perform various services; and c) Sterling Lexicon may be required to comply with certain legal or governmental obligations.
Lexicon Relocation, LLC d/b/a Sterling Lexicon and Sterling Relocation Ltd (collectively, Sterling Lexicon) participates in and has certified its compliance with the EU-U.S. and the Swiss-US Privacy Shield Framework. Sterling Lexicon is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
Sterling Lexicon is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Sterling Lexicon complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Sterling Lexicon is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Sterling Lexicon may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Sterling Lexicon has further committed to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner for Swiss employee with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
We may collect personally identifiable information such as SSN, government ID, employee data, bank account information, passport number, names, postal addresses, email addresses, etc. ("PII"), when voluntarily submitted by our visitors. We may also collect sensitive personal data such as racial and ethnic information if we are requested to provide visa and immigration services, as well as, religious information if requested to assist with finding appropriate schooling or places of worship.
The information you provide is used to facilitate the relocation services that we provide to you or as part of your employment benefits and compensation. This information is only used to fulfill your specific request unless you give us permission to use it in another manner (ex. to add you to one of our mailing lists). We do not share, sell, rent or trade PII with third parties for their promotional purposes. We will share your personal information with third parties only in the ways that are described in this Policy (see the section entitled "Service Providers" below).
Technologies such as cookies, beacons, tags, scripts or similar technologies are used by Sterling Lexicon and our marketing partners, affiliates, and customer support. These technologies are used in analyzing trends, administering the Site, tracking users' movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
As is true of most web sites, we gather certain information automatically and store it in log files. This information includes, but may not be limited to, Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
We may partner with a third party to either display advertising on our Site or to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.
To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your PII from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all users to exercise caution when providing personal information in the blogs or community forums.
We may use third parties to facilitate and provide corporate relocation services, such as making arrangements for transportation, home marketing assistance, home finding assistance, mortgage assistance, rental assistance, international visa and work permit coordination, international destination services, financial services to foreign nationals in the United States, departure services and repatriation services on our Site. When, pursuant to your relocation policy, you are entitled to any of the services listed above, we will share only that PII which is relevant to the specific relocation services being provided by the third party. These third parties are authorized to use your personally identifiable information only as necessary to provide these services to us and for no other purpose.
We will share your personal information with third parties only in the ways that are described in this Policy. We do not sell your personal information to third parties. We reserve the right to disclose your PII (i) to governmental agencies or other companies assisting us in fraud prevention or investigation; (ii) as required by law; and (iii) when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Site. We will only disclose PII to governmental agencies or other companies when trying to protect against or prevent actual or potential fraud or unauthorized transactions or investigating fraud which has already taken place. PII is never provided to these governmental agencies or companies for marketing purposes. We may also disclose your personal information to any other third party with your prior consent.
Your PII is kept secure. Only authorized employees, agents and contractors (who have agreed to keep information secure and confidential) have access to this information. Emails generated by the Site are for the sole purpose of facilitating your relocation services. An opt-out option is available to you through your relocation consultant. Opting out may cause interruptions in, and/or loss of, relocation benefits provided to you by your employer. Please contact your relocation consultant or call (904) 858-1255 for more information on opting out.
The security of your PII is important to us. When you enter sensitive information (such as bank account information) on the Sterling Lexicon 360° portal, we encrypt that information using transport layer security technology ("TLS”). To learn more about TLS, follow this link: http://www.webopedia.com/TERM/T/TLS.html
We follow generally accepted industry standards to protect PII submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can email us at email@example.com.
Sterling Lexicon acknowledges that you have the right to access your personal information. Upon request Sterling Lexicon will provide you with information about whether we hold any of your personal information. You can update, change or delete your PII by accessing Sterling Lexicon360° and signing in using your username and password. Once you sign into Sterling Lexicon360°, you can update your PII by clicking on the "My Profile" button and then the "Start Change Request" button. You also have the right to request a copy of all PII that you have provided to us, as well as, have Sterling Lexicon transmit such personal data directly to another controller.
When the purpose for processing your PII is based on consent, you have the right to withdraw consent at any time. In certain circumstances, however, we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service, resolve disputes or enforce our agreements. When the purpose for processing your PII is based on contract, we may not be able to continue providing services to you without such personal information and we may have to terminate our relationship.
Please note that for personal information about you that we have obtained or received for processing on behalf of Client (controllers who determined the means and purposes of processing) all such requests should be made to Client directly. We will honor and support any instructions they provide us with respect to your personal information.
Sterling Lexicon collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
If you forget your password when signing into Sterling Lexicon360°, there is a link you can click on which will email you a new password. If you forget your username, you need to contact your relocation counselor.
We will retain your information for only as long as necessary for legitimate business purposes, or as necessary to comply with our legal obligations, resolve disputes or enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us at firstname.lastname@example.org.
You may sign-up to receive emails, newsletters or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our website or by contacting us at email@example.com.
The Site is not directed at or intended for children under the age of 13. We do not knowingly collect personal data on the Site directly from children and will destroy such information if we become aware that a child has disclosed such information to us without consent from a parent or guardian.
California Civil Code Section § 1798.83 permits users of our sites or services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Privacy@sterlinglexicon.com or contact us as described in this Privacy Notice.
Currently, various browsers offer a “do not track” or “DNT” option which sends a signal to websites visited by the user about the user's browser DNT preference setting. We do not currently commit to responding to browsers' DNT signals with respect to the Sites, in part, because no common industry standard for DNT has been adopted, including no consistent standard of interpreting user intent.
We reserve the right to modify this Policy at any time, so please review it frequently. If we make material changes to this Policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective. Any changes to the Policy will only apply to activities and information on a going forward, not retroactive, basis.
By e-mail: firstname.lastname@example.org
By Phone: (904) 858-1255
By Mail: Lexicon Relocation, LLC, 815 South Main Street, Jacksonville, Florida 32207
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If you are a EU resident or citizen, and you would like to act on your Individual Rights (modify, access, or portability) please click here and fill out the form. Once we receive the completed form your request will be processed within 30 days (for small changes) or 90 days (for more complex requests).
Should you wish to take any complaints or questions further, you have the right to contact your local data protection regulator (which, in the UK, is the Information Commissioner's Office) regarding such issues.