EMEA/APAC PRIVACY POLICY

    Effective Date

    Effective Date: May 21, 2018
    Last Updated: December 19, 2019

    Your continued use of the Site signifies consent to this Policy as may be amended from time to time.

    Thank you for visiting our websites (the “Sites”). This Privacy Policy (“Policy”) applies to www.sterlinglexicon.com and portal.sterlinglexicon.com which are owned by Sterling Relocation Limited and Sterling Relocation Americas, Inc. (collectively, “Sterling”, “we”, “us”, or “our”).

    This Policy is posted to comply with the European Union’s General Data Protection Regulation and the European Union Withdrawal Act 2018 (“UK GDPR” and collectively, “GDPR”) and the California Consumer Privacy Act (“CCPA”), and describes how we collect, use, share and secure the personal information that may be used to identify you as a visitor to the Site or that you provide as our customer. It also describes your choices regarding use, access, correction, deletion and transfer of your personal information.

    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 that our clients (“Client”) have engaged Sterling to provide. Note: the privacy practices set forth in this Policy are for our Sites only. If you link to other websites, please review the privacy policies posted on those web sites.

     

    Legal Basis of Processing

    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 Sterling to perform various services; and c) Sterling may be required to comply with certain legal or governmental obligations.

     

    EU-US and Swiss-US Privacy Shield

    TRUSTe

    Sterling Relocation Ltd, and Sterling Relocation Americas, Inc. (collectively, “Sterling”) participates in and has certified its compliance with the EU-U.S. and the Swiss-US Privacy Shield Framework. Sterling is committed to subjecting all personal data received from the United States, the European Economic Area (EEA), the United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework and to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list. In the event of a “No Deal Brexit,” Sterling will continue to comply with the GDPR.

    Sterling 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 complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA, the United Kingdom and Switzerland, including the onward transfer liability provisions.

    With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Sterling is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Sterling 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, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

     

    Collection and Use of Information

    Collection of Information - We may collect the categories of personally identifiable information (PII) listed below when voluntarily submitted by our visitors to the Sites:

    • Name and Role details: name; username/login credentials/password (if you have access to our portal); work/company information (job title/level);
    • Contact details: email; mailing/work address; tel./fax number; device ID; IP address; as well as imported contacts when done with notice and affirmative permission of the user;
    • Personal Characteristics/Demographic information: age; gender; place of birth; marital status; domicile/nationality; job title; language selections; immigration status; and work/professional experience;
    • Financial information: Financial account number; credit/debit card number; salary/compensation;
    • Transactional and purchase/payment details: billing address; payment method; account holder information; and credit or debit card numbers;
    • Employer/employee information: start dates, salary, company name, and titles;
    • Education and Training: Schools/universities attended; course of study; academic grades/rankings/degrees obtained; professional certifications/licenses/memberships; publications; and training programs;
    • Identification numbers: Social Security Number (SSN/TIN), passport number, driver's license number/VIN; national ID number;
    • Biometric and Genetics: Facial photographs (passport details page)
    • Customer service information: or for newsletters or marketing efforts;
    • Usage data: relating to visits, clicks, downloads, messages sent/received, and other usage of sites, mobile apps, platforms, and services offered by the customer.
    • Server log file info: automatically gathered server log file information when user visit websites, including IP address, time/date stamp, browser type, referring and exit web pages, the files viewed on our sites and services (e.g., HTML pages, graphics, etc.), and your operating system;
    • CRM information: customer relationship data and business account/sales information; influence ranking; product utilization ranking; and purchase amount ranking; and
    • Religion/Politics/Philosophical/Union information: and other "special categories"-type pieces of information.

    We may also combine the information we collect about you with demographic, geolocation, and interest-based segment data, along with event-based data from third-party providers.

    Use of Information - The information you provide is used:

    • To provide services you have requested or purchased;
    • To communicate with you about our current offerings and services;
    • To authenticate users, and to prevent and detect fraud and misuse of our Sites and services;
    • To evaluate the performance of our sites and services;
    • To comply with legal requirements;
    • To measure performance;
    • To provide customer service support or to respond to your inquiries;
    • For marketing purposes, and to inform you on global mobility trends or industry insights.
    • In other ways, in accordance with your consent.

     

    Cookie/Tracking Technology

    Technologies such as cookies, beacons, tags, scripts or similar technologies are used by Sterling and our marketing partners, affiliates, and customer support. These technologies are used to maintain or analyse the functioning of the Sites or online service, serve contextual advertising on the Sites or online service, authenticate users of, or personalise the content on, the Sites or online service, or contact the individual. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

    We use cookies to remember a user’s settings (e.g. language preference), and for authentication. You can control the user of cookies at the individual browser level; however, if you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited.

    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 click stream 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.

    Interest-Based Advertising  - 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.

    To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

    Please note this does not opt you out of being served ads. You will continue to receive generic ads.

     

    Sharing of Information

    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).

    Service Providers
    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, 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 authorised to use your personally identifiable information only as necessary to provide these services to us and for no other purpose.

    Distribution of Information
    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, public authorities, 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 unauthorised 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.

    Social Media Widgets
    Our Sites includes Social Media features, such as the LinkedIn and Twitter buttons. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social Media Features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

    Blogs
    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 indefinitely. To request removal of your PII from our blog or community forum, contact us at privacy@sterlinglexicon.com. 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.

     

    Commitment to Data Security

    We use reasonable measures to safeguard the security and integrity of your PII. Only authorised employees, agents and contractors (who have agreed to keep information secure and confidential) have access to this information. The security of your PII is important to us. When you enter sensitive information (such as bank account information) on the Sterling portal, we encrypt that information using transport layer security technology (“TLS”) and Secure HTTP. 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. 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 privacy@sterlinglexicon.com.

     

    Accessing, Updating, Deleting and Transferring Your PII

    Sterling acknowledges that you have the right to access your personal information. Upon request Sterling will provide you with information about whether we hold any of your personal information. You can update, change or delete your PII by accessing the assignee portal and signing in using your username and password. Our portal is available at portal.sterlinglexicon.com. Once you sign into the portal, you can update your PII. For GDPR data subjects, you also have the right to request a copy of all PII that you have provided to us, as well as, have Sterling transmit such personal data directly to another controller.

    If you forget your password or username when signing into the assignee portal, there is a link you can click on which will email you a new password. 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.

     

    Our Service Platform

    Sterling collects information under the direction of its Clients, and has no direct contractual relationship with the individual whose data it processes. If you are an employee of one of our Clients and do not want Sterling to process your PII, please contact your employer (Sterling’s Clients) directly. Sterling may transfer PII to companies that help us provide our services. Transfers of PII to subsequent third parties are covered by the service agreements with our Clients.

     

    Data Retention

    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 privacy@sterlinglexicon.com.

     

    Marketing Preferences

    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 Sites or by contacting us at privacy@sterlinglexicon.com.

    Emails generated by the Sites are for the sole purpose of facilitating your relocation services. An opt-out option is available to you through your relocation consultant. Opting out of emails related to your relocation services may cause interruptions in, and/or loss of, relocation benefits provided to you by your employer. Please contact your relocation consultant or call +44 (0) 20 8841 7000 for more information on opting out.

     

    Children’s Online Privacy

    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 Privacy Rights

    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.

     

    Changes to this Privacy Policy

    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. Any changes to the Policy will only apply to activities and information on a going forward, not retroactive, basis.

     

    Contact Us

    If you have any questions, concerns, or comments about our privacy policy or how we use your information, you may contact us using the information below:

    By e-mail: privacy@sterlinglexicon.com
    By Phone: +44 (0) 20 8841 7000
    By Mail: Sterling Relocation, Limited, Hallmark House, Rowdell Road, Northolt, UB5 6AG, UK

    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 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.

     

    More information


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