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.
Collection of Information
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. 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).
Cookies, Internet-related information and “Do Not Track”
A cookie is a small text file that may be placed in your browser by websites you visit and the content partners for those sites. Cookies help websites remember visitors when they return to the site. For example, a cookie can help a website remember that you’ve already registered, so you don’t have to sign in again each time you visit. Essentially, cookies are used to customise websites based on the content you view and the preferences you have indicated.
We may use the following cookies on the Websites:
Strictly necessary cookies. These are cookies that are required for the operation of the Websites. They include, for example, cookies that enable you to log into secure areas of the Websites, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Websites when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to the Websites. This enables us to associate individual customers with their information profiles or personalise our content for you, greet you by name and remember your preferences (for example, a choice of language or region).
In addition, the Web servers for some of the Websites use an extended log file format which captures other information about your activity on those Websites including the date and time of visit; referring address (location from which a visitor comes to our site); type of Internet browser; and Internet Protocol (IP) address. The log file does not capture your email address or other information identifying you. We use this information to maintain and secure the Websites, monitor usage patterns, protect our intellectual property, and improve the appearance and content.
“Do Not Track” is an initiative to develop a signal for an Internet user to notify websites that he or she does not wish to be tracked by third parties. More information on the initiative is available here: http://www.w3.org/2011/tracking-protection/. Do Not Track has not yet been standardized because the initiative has not yet come to a consensus on exactly how websites should respond to these types of signals. Like many other websites, the Websites do not respond to Do Not Track signals.
Social Media Widgets
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 GDPR@sterling.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 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 authorized 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 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.
Commitment to Data Security
We use reasonable measures to safeguard the security and integrity of your PII. Only authorized 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 on the Sterling portal, we encrypt that information using secure socket layer technology (“SSL”) and Secure HTTP. To learn more about SSL, follow this link: http://www.webopedia.com/TERM/S/SSL.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 GDPR@sterling.com.
Accessing, Updating 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 also update, change or delete your PII by emailing GDPR@Sterling.com
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.
Our Service Platform
Sterling 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 in to Sterling Portal, 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 GDPR@Sterling.com.
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 GDPR@Sterling.com.
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.
Sterling Tax Strategy: Compliant, open and fair
Compliance with tax law and practice is a fundamental part of being a responsible, professional organisation. Compliance means paying the right amount of tax at the right time and disclosing all relevant facts to the tax authorities, but also claiming reliefs and incentives where available and fair. We use external tax advisors to ensure our continuing compliance and to provide advice where material tax uncertainties and risks are identified.
Due to the international and bespoke nature of the services we provide, tax laws are one of the many factors considered when we structure our commercial activities. All of our activities have commercial and economic substance. Tax planning does not result in complex or artificial transactions or structures.
Our tax procedures and dealings with tax authorities are the responsibility of our finance department under the oversight of the board. Communications with the tax authorities are based on honesty, transparency and cooperation.
Privacy Contact Information
By e-mail: GDPR@Sterling.com
By Phone: +44 (0) 20 8841 7000
By Mail: Sterling Relocation, Limited, Hallmark House, Rowdell Road, Northolt, UB5 6AG, UK
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.