At Stein IAS’s (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other relevant and applicable laws and regulations of the United Kingdom.
The individuals from which we may gather and use data in the context of this website are:
any other people that the organisation has a relationship with or may need to contact.
As your Data Controller, Stein IAS will determine the purposes for which and the manner in which any Personal Data is processed. Additionally, Stein IAS will be responsible for your personal data as well as compliance with data protection principles.
|Address:||Stein IAS Holdings LTD, 34 Bow Street, London, WC2E 7AU|
|Privacy Contact Email:||firstname.lastname@example.org|
|ICO Registration Number:||Z567110X|
Any inquiries about your data should be sent to the above email. It can also be sent directly to the company, if you prefer, in a letter to the listed address. We cannot guarantee prompt responses if physical mail is your chosen method of communication.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
While managing our responsibilities as a Data Controller, we have third party providers who will deal with your data on our behalf (known as “Processors”). The responsibilities described below may be assigned to a processor, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it from you:
For further information on the legal bases and what they mean, please refer to section 2.2 below.
During the course of our normal business activities Stein IAS will not collect any special categories of Personal Data according to the UK GDPR.
Stein IAS will access and use your personal data only for the purposes for which you have submitted it to us to (a) provide information to you, (b) make contact with you, (c) provide services to you, or (d) maintain the operations and security of the website and services we provide to you. We will not use your personal information for any other purposes, for example for the communication of marketing materials, unless we have your specific consent that permits us to do so.
There are several justifiable reasons under the UK GDPR that allow the collection and processing of Personal Data. The main bases we rely upon are the following:
To see which basis applies to your processing case, please refer to section 2.1
We primarily obtain the data from you (including via the devices you use) while visiting the site. If we do not collect the personal data directly from you, we will also tell you the source of the personal data and, if applicable, whether it is sourced from publicly available sources.
When processing your data, we work with service providers who have access to your data. The categories of recipients are as follows:
The table below lists the specific providers we use that you are likely to interact with while visiting our website.
|Purpose||Third parties inolved|
|Web hosting||IOMart Cloud Services|
|Ads/targeting||Google Analytics, Hotjar, Eloqua, LinkedIn|
For the purposes of fulfilling the contract, we may also disclose your personal data to anyone to whom we assign rights arising from the contractual relationship with you. In these instances, you will be directly informed.
You will receive marketing and new content communications from us if you opt into receiving those communications. We may make suggestions and recommendations to you about goods or services that may be of interest to you, but only if we have a reasonable expectation that you would benefit from or be interested in these services in line with the PECR. The lawful basis for this processing is legitimate interest, and a complementary legitimate interest assessment will be conducted when required.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
As a data subject under the UK GDPR, you may have the right in law to:
To exercise these rights, you can send an email to us at any point at the following email address: email@example.com.
We will handle any request to exercise these rights in accordance with the relevant laws, but please note that these rights may not be absolute. Stein IAS may refuse or deny a request in accordance with these rules, though where possible you will be informed why this is happening.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may also need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response
You have the right to object at any time, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the UK GDPR; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise, or defence of legal claims.
If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling that is related to direct marketing.
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. When we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.
However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Stein IAS to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us at firstname.lastname@example.org.
You can ask us to stop sending you marketing messages at any time by unsubscribing.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
We share non-Personal Data with third parties. We may share your Personal Data with subcontractors when necessary and with your consent. The sub-contractors are also subject to our confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.
We may also share Personal Data with interested parties in the event that Stein IAS anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
Stein is a part of the MSQ Partners Limited group of companies. MSQ is a group of controlled undertakings which, in accordance with the UK GDPR Art. 4 (19), Recital 37 + 48, allow for a legitimate interest in sharing certain personal data within the group. This data sharing is limited to what is necessary, and primarily applies to your application to a job position at Stein. Your data will not be shared with other agencies within the group or with no purpose. If your data is to be shared, you will be provided with notice.
On occasion, personal data may be accessed or processed by Stein IAS International LLC , based in the United States of America. Stein IAS International LLC ensures that all Article 46 requirements are met when data is transferred, covering the collection, use and retention of personal data transferred from the UK & European Union to the United States.
Stein IAS International LLC may access and use your personal data only for the purposes for which you have submitted it to us to (a) provide information to you, (b) make contact with you, (c) provide services to you, or (d) maintain the operations and security of the website and services we provide to you. Stein IAS International LLC will not use your personal information for any other purposes, for example for the communication of marketing materials, unless we have your specific consent that permits us to do so.
We store your personal data only as long as it is necessary to achieve the purpose of processing. In most normal cases, we store your data if you have consented to the processing until you revoke your consent. If we need the data to perform a contract, we retain the data for as long as the contractual relationship with you exists. If we use the data on the basis of a legitimate interest, we will retain your data for as long as your interest in deletion or anonymization does not prevail. Stein IAS maintains a retention policy and schedule to ensure that data is not kept longer than is necessary.
In addition, data may be stored beyond the outlined periods in certain rare circumstances where data must be kept in order to exercise legal rights or to comply with other legal obligations. In these cases, the data is deleted when a storage or retention period prescribed by law expires.
We store applicant documents for a period of six months if the application does not lead to an employment relationship and no further storage has been agreed.
Cookies are small text files sent by us to your computer, and from your computer or mobile device to us each time you visit our website. They are unique to you or your web browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser session. Persistent cookies last until you or your browser delete them, or until they expire.
Please view our for further information.
There is a transfer of data to third countries outside of the United Kingdom and European Union. Information we collect from you could be processed in the United States or other third countries. Some third countries, such as the United States, have not currently received an adequacy decision from the European Union or UK under Article 45 of the GDPR which means that your data may not receive the same level of protection there as it does under the UK GDPR and European GDPR.
Stein operates an office in the united states,and if you are a visitor from certain states you may have data privacy rights.
California - CCPA & CPRA
Under California law, California residents are entitled to ask us for a notice identifying the categories of personal customer information that we share with certain third parties for marketing purposes, and providing contact information for such third parties. This information is available above, but if you would like it in more detail please submit a written request to us via email at [EMAIL ADDRESS]. You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
California has passed a law called the California Consumer Privacy Act (CCPA). If the CCPA is applicable to you, you have the right to:
“Personal Information” is defined to include information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household. This includes (among other types of personal information) IP addresses, geolocation data, biometric information, and “unique identifiers” such as device and cookie IDs, Internet activity information like browsing history, commercial information such as products or services purchased or consuming histories or tendencies, and characteristics concerning an individual’s race, color, sex (including pregnancy, childbirth, and related medical conditions), age (40 or older), religion, genetic information, sexual orientation, political affiliation, national origin, disability or citizenship status. Inferences drawn from personal information “to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes” are also considered “personal information.”
Contact us at email@example.com to exercise your CCPA rights.
Request for Erasure. For identity verification purposes, we requires anyone submitting an erasure request to submit the subject’s full name, email address, and home address related to the subject’s Stein communications or relationship. We rely upon this information to ensure the information on the correct individual is removed.
Do Not Sell My Information. We take your privacy seriously. We do not sell our members information. We are not a data broker.
If you are a California resident, you can request information regarding the disclosure, if any, of your personal information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org, subject line: CCPA Request.
You may review and request changes to your information or opt-out of the sale of your personal information at email@example.com.