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Privacy & Compliance

PRIVACY POLICY

Thank you for visiting our website (the “Site”). This Privacy Policy (“Policy”) applies to www.Sterling.com which is 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 (“GDPR”), and describes how we collect, use, share and secure the personal information that may be used to identify 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 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 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).

Cookie/Tracing 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 in analysing 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.
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 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 wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Social Media Widgets

Our Site 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. To request removal of your PII from our blog or community forum, contact us at privacy@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.

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 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 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.

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. 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 +44 (0) 20 8841 7000 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 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 privacy@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 update, change or delete your PII by accessing the assignee portal and signing in using your username and password. Once you sign into the portal, you can update your PII. 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.

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 contractual relationship with you. 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 Client) 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.

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

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@Sterling.com.

Opt-Out

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 privacy@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.

Privacy Contant Information

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

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.

Effective Date

The effective date of this Privacy Policy is May 21, 2018. Your continued use of the Site signifies consent to this Policy as may be amended from time to time.

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.

More information

Data Subject Consent Form – ENG Data Subject Consent Form – ESP Data Subject Consent Form – FR Data Subject Consent Withdrawal Form – ENG Data Subject Consent Withdrawal Form – ESP Data Subject Consent Withdrawal Form – FR Sterling Anti Bribery & Anti Corruption Charter Sterling Environmental Policy BAR Code of Practice The FIDI Anti-trust Charter

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