Introduction

This Privacy Policy aims to help you understand the personal information collection, use, disclosure and retention practices of Stephen L Rose, Inc. By providing personal information to us (whether via our website, by email, in person or over the phone), you agree to the processing set out in this Privacy Policy. The websites of other Stephen L Rose affiliates are governed by separate terms of use and privacy policies.

Personal Information

Personal information is information about an identifiable individual. Depending on local law, publicly available information, such as business contact information, including your name, title or position, business, telephone or facsimile number, may not be considered personal information.

What personal information do we collect?

We may collect and process different types of personal information in the course of operating our business. These include:

• Contact information such as name, email address and telephone number;
• Biographical information such as job title, employer, professional associations, or regarding membership in industry trade groups;
• Your attendance at conferences or trade shows;
• Data from any surveys or questionnaires that we may have provided to you;
• Past requests that you may have made for information from us;
• Recruitment information such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment or association to or with Stephen L Rose;
• Unique IDs such as your mobile device identifier or cookie ID on your browser;
• IP address and information that may be derived from IP address, such as geographic location;
• Information about the content you access on our website and the nature of your visit, including the time of your visit to our website (by day, week, and duration) and whether you are a new visitor or a returning visitor;
• Information about a device you use, such as browser, device type, operating system, the presence or use of apps, screen resolution, and the preferred language.

How do we use personal information?

We may use personal information in the manner set out below. In each case, we identify the grounds that we rely on to use your personal information:

• To facilitate use of our website and social media channels and to ensure content is relevant—to tailor content that we may show you on our website and via our social media channels, to respond to requests for information or enquiries from visitors to our website, to ensure that content from our website is presented in the most effective manner for you and for your device and for analytical purposes to better understand digital interactions with our company. Applicable legal grounds: legitimate interests (to allow us to provide the content on the websites), consent, contract performance;
• For marketing and business development purposes—to administer subscriptions to our newsletters, social media channels, and other resources that you may subscribe to, updates and invitations to user seminars, webinars and events which you have chosen to receive. Applicable legal grounds: legitimate interests, consent;
• For recruitment purposes—to enable us to process applications for employment and to assess suitability for any position for which an individual may apply at Stephen L Rose. Applicable legal grounds: legitimate interests (to ensure that we can make the most appropriate recruitment decisions for Stephen L Rose), contract performance (in order for us to take steps to enter into a contract with someone who requested it);
• To fulfil legal or risk management obligations—for relevant background checks as may be required by applicable law, regulation and best practice at any given time, as well as to enforce our legal rights and/or to protect the rights of third parties. Applicable legal grounds: legal obligations, legal claims, legitimate interests;
• To establish and maintain commercial relationships with vendors and other third parties—to process and receive payments, evaluate credit standing and to recover any payments due to us and, where necessary, to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings). Applicable legal grounds: contract performance, legal claims, legitimate interests (to ensure that we are paid amounts due);
• To reorganize or make changes to our business—in the event that we undergo a reorganization (for example if we merge, combine or divest a part of our business), we may need to transfer some or all of personal information to the relevant third party (or its advisors) as part of any due diligence process or transfer to that reorganized entity or third party your personal information for the same purposes as set out in this Privacy Policy or for the purpose of analyzing any proposed reorganization. Applicable legal grounds: legitimate interests (in order to allow us to change our business).

Duration of processing

Stephen L Rose maintains personal information only as long as it is required to fulfill the purpose under which it was gathered, unless required by law to retain for longer periods or other purposes.  Where Stephen L Rose determines that personal information is no longer required, we will securely destroy such information as soon as it is commercially reasonable to do so.

Sharing of information

We may also share personal information with certain third parties such as:

• Third-party service providers who provide website, application development, hosting, maintenance, and other services to us, including allowing us to analyze the usage of our website, engagement on our social media channels and our ability to effectively communicate with potential vendors. These third parties may have access to, or process personal information as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information;
• Law enforcement and governmental entities when required by law. For greater clarity, we may disclose personal information or other information if required to do so by law or in the good faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies; and
• An acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Selling of personal information

Stephen L Rose does not collect any personal information for the purpose of selling that personal information.  Despite this, some jurisdictions require us to make the following additional statements:

• We have not sold any personal information in the past twelve months.
• We do not sell personal information to third parties.

Requesting access, changes, or limits to your information

Under applicable law, you may request from us the following:

• a copy of any of your personal information which we may have;
• to update or correct any inaccuracies in your personal information that we may have;
• to request that we limit our use of your personal information, including but not limited to instructing us not using your personal information for a specific purpose;
• to erase some or all of your personal information that we do not have a legal entitlement to keep; or
• withdraw any previously provided consent for our use of your personal information.

To make any of the above requests to access, change, or impose limits on the use of your personal information, please contact us at stephen@stephenlrose.com with details of your request.  For the purposes of verifying your identity we may ask that you provide us sufficient personal details to allow us to identify you, which may include but may not be limited to your full legal name, your email address, your phone number, and/or your mailing or physical address.  Such information will only be used for the purpose of verifying your identity.

In addition, while Stephen L Rose does not sell personal information to third parties, some jurisdictions still require that we provide you a means to opt out of the sale of your personal information to third parties.

What are cookies and how are they used?

Cookies are unique identifiers or tokens of agreement from a web server that are saved in a small text file on your computer when you access a Stephen L Rose web site through a browser. We can use this information to track visits to web pages (which ones, how many times) or to personalize web page content.

Most major web sites use cookies and most browsers are set up to accept them. If you wish, you can reset your browser to refuse to accept cookies or to notify you when a cookie is being sent-see “Help” in your browser. You do not need cookies to visit our web sites. However, if you do not accept cookies, you may not be able to use some of the features on the web sites.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

We currently use the following cookies:

How to contact us?

If you have any questions, comments, or suggestions related to data privacy, please contact us at:

Email: stephen@stephenlrose.com

Updates to this Privacy Policy

We may change the content of our websites and how we use cookies without notice and consequently our Privacy Policy may change from time to time in the future. We therefore encourage you to review them whenever you visit the website to stay informed of how we are processing personal information.