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VIRTUAL DATA ROOM PRIVACY POLICY

VIRTUAL DATA ROOM PRIVACY POLICY OF STERLING TECHNOLOGY LTD.

1. DATA COLLECTED

Without limitation, any of the following Data may be collected:

1.1. Name, company, role, contact information, location;

1.2. IP address (automatically collected);

1.3. Web browser type and version (automatically collected)

1.4. Operating system (automatically collected);

1.5. Your document review activity within each Project on the Platform; and

1.6. Cookie information (see clause 8 below).

2. OUR USE OF DATA

2.1. We retain the Data indicated in clause 1 of the Policy indefinitely, unless requested otherwise. This is because Users often return to our Platform for future deals, which can happen several years later. Storing this Data ensures return visits to the Platform are as user-friendly as possible. If you would like to see, edit, or request we delete your data, we will happily facilitate this: support@sterlingvdr.com.

2.2. Unless we are obliged or permitted by law to do so, and subject to clause 3, we will not share your Data with any third parties.

2.3. All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998 and are compliant with the GDPR as of 25 May 2018. For more details on security, see clause 7 below.

2.4. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Platform. Specifically, Data may be used by us for the following reasons:

2.4.1. Internal record keeping;

2.4.2. Improvement of Sterling’s products/services;

2.4.3. Transmission by email of Sterling promotional materials that may be of interest to you (only if you have explicitly consented to receive them);

2.4.4. Contact for market research purposes which may be done using email, telephone or mail. Such information may be used to customise or update the Platform.

3. CHANGES OF BUSINESS OWNERSHIP & CONTROL

3.1. Sterling may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division. The new owner, or newly controlling party, will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.

3.2. In the event that any Data submitted by Users is transferred in accordance with clause 3.1, we will as soon as reasonably possible inform you of the changes.

4. CONTROLLING ACCESS TO YOUR DATA

You will be given options to restrict our use of Personal Data for direct marketing purposes only. For more information see clause 6.2.

5. YOUR RIGHT TO WITHHOLD INFORMATION

5.1. In order to use all Services and Systems available on the Platform you shall be required to submit Account information or other Data.

5.2. You may restrict your internet browser’s use of Cookies. For more information, see clause 8.4 below.

6. ACCESSING YOUR OWN DATA

6.1. You may access your Account at any time to view or amend the Data we hold for you. You may need to modify or update your Data if your circumstances change.

6.2. Additional Data as to your marketing preferences will also be stored by us. You may change these preferences at any time directly via the unsubscribe link at the bottom of marketing emails.

7. SECURITY

7.1. Data security is of great importance to Sterling and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online.

7.2. Specifically, we utilise the following system: 8.2.1 ISO Information security management – BS ISO 27001:2005.

8. COOKIES

A cookie is a small file that resides on your computer’s hard drive and often contains an anonymous unique identifier. This does not result in a negative impact to performance or security. For more information about cookies, visit http://www.allaboutcookies.org/cookies/

8.1. We use Cookies when a User joins our Platform for the first time.

8.2. You may delete Cookies at any time, but it will impact your experience – for example, it will mean typing in your details every time you log in.

8.3. By default, your browser will accept Cookies. If you would like to change these settings, consult the help menu in your browser.

Read our full cookie policy here: https://www.sterlingvdr.com/cookie-policy

 9. CHANGES TO THIS POLICY

Sterling reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Platform and you are deemed to have accepted the terms of the Policy on your first use of the Platform following the alterations.

 10. DEFINITIONS & INTERPRETATION

Account: collectively the personal information, Payment Information and credentials used by Users to access material and/or any communications System on the Platform;

Content: any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of the Platform;

Cookie: a small anonymous text file placed on your computer by Sterling when you visit certain parts of this Platform. This allows us to offer the advanced functionality required for your business purpose. Further details are contained in clause 8 of this Policy;

Data: collectively all information that you submit to the Platform. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;

Disclaimer: the specific terms and conditions governing your use of a Project within the Platform;

Project: a secure data room within the Platform that has been made available for access by you subject to the terms of the appropriate Disclaimer;

Service: collectively any data room, online facilities, tools, services or information that Sterling makes available through the Platform either now or in the future;

Sterling: Sterling Technology Limited operating under its trading name Sterling Data Rooms. All expressions of “we” and “us” are references to Sterling;

System: any online infrastructure that Sterling makes available through the Platform either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;

User/Users: any third party that accesses the Platform. The expression “you” is a reference to such a user; and

Platform: means the Sterling data room site (vdr.sterlingdatarooms.com) and any sub-domains of this site unless expressly excluded by their own terms and conditions.

 

 

 

 

Last updated 18.08.18.