Privacy Policy

I. Introduction

Sterling-Rice Group, Inc. (“SRG,” “us,” “our,” or “we”) respects your privacy and is committed to protecting it through its compliance with this Privacy Policy (the “Privacy Policy”). This Privacy Policy describes the types of information SRG may collect from you or that you may provide when you visit, access, or use the Website, www.srg.com (the “Website”), and any other of SRG’s content, functionality, services, client portal, online or mobile apps (collectively, the “Service”), and SRG’s practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy does not cover any information collected through other websites or apply to third-party affiliates that may collect information on their own behalf unless explicitly stated at the time of collection.

Please read this Privacy Policy carefully to understand SRG’s policies and practices regarding your information and how SRG will treat it. If you do not agree with SRG’s policies and practices, your choice is not to use SRG’s Service. By accessing the Website or using SRG’s Service, you agree to this Privacy Policy. This Privacy Policy may be updated from time to time at SRG’s sole discretion (see the Changes to the Privacy Policy section below). Your continued access of the Website and/or use of SRG’s Service after SRG makes changes to this Privacy Policy is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

II. Information Collected

Information You Provide Us

You are not required to provide information about yourself in order to visit the Website. However, if you use our Service, you will need to provide SRG with personal information such as your name, address, email address, and phone number. You may also choose to provide us with personal information when you contact us in order to respond to questions about the Website, Service, or other general inquires. In addition, when you make a purchase through the Website for our Service, you must provide certain billing and payment information, which may include instructions for a wire transfer and/or ACH transfer.

Information Collected Automatically

As you use the Service and the Website, SRG may collect or obtain certain information about you automatically, including:

In addition, when you use the Service and Website, information may be collected in the following manner:

Google Analytics

SRG uses Google Analytics on our Website. When you access the Website, we automatically collect information such as device type, browser, IP address, and location using cookies, session IDs, and web beacons through Google Analytics’ services. This information is stored in the United States on Google’s servers. Google may send your information to third parties that handle data, including to ad server providers or when required by law. We use Google Analytics to improve the user experience of the Website, identify problems and observe usage trends such as time spent on page, path taken, and number of visits. You may opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout?hl+en=GB

Cookies

The Website also uses cookies. Cookies are small files that are saved on your computer’s hard drive when you visit some sites. These cookies help give you faster access to pages you have already visited. They also allow you to personalize your pages and optimize your experience at the Websites. You can disable cookies on your computer by indicating this in the preferences or options menus in your browser or consulting the Help section of your specific browser. Disabling cookies may prevent you from properly using the Website or Service. You can learn more about cookies and how to manage them at https://www.allaboutcookies.org/

Session ID

Session IDs allow us to identify a user across multiple webpage requests. This session ID is maintained within your cookie file, where possible. If cookies are not enabled or if the user’s internet browser program does not support cookies, then SRG will place the session ID in the requested webpage. This allows the end user to avoid having to continually reenter certain information such as account name and password for every webpage request. This session ID “expires” whenever the user closes their internet browser.

Web Beacons

Also called “single-pixel gif,” “pixel tags,” or “clear gif,” these allow us to gather non-personally identifiable traffic statistics and other aggregate information about visitors to the Website. SRG (through itself or third parties) uses this technology to collect and accumulate anonymous data that helps us understand and analyze the experience of people visiting the Website and, along with other information you provide, customize your future visits and improve the Website. For example, we capture data on the type of browser used, operating system software (e.g., Windows OS version, Mac OS version), cookie preferences (whether the user has them turned on or off), and search engine keywords (what words did a visitor use to find the Website).

IP Address

Each time you visit the Website, we automatically collect your IP address and the site you came from. In order to administer and optimize the Website for you and to diagnose problems with the Website, we use your IP address to help identify you and to gather broad demographic information about you.

Direct Linking URLs or Hotlinking

To provide more relevant advertising, SRG may gather data from the referrer logs that identify where and how frequently user images being hosted by SRG are being displayed on third-party sites.

Banner Ads

The Website and Service may include the use of ad banner partners for the serving and/or targeting of ads, promotions, and other marketing messages. These ads may be provided, in some cases, by a third-party ad service provider. The ad service provider may place or utilize their own unique cookie on your browser and may use non-personally identifiable information about your visit to the Website, such as the number of times you have viewed the ad. SRG is not responsible for the collection of these cookies and is not responsible for the actions of the ad service providers. SRG does not sponsor, endorse, or guarantee any products or services advertised by third parties on its site.

III. How We Use the Information Collected

Aggregation: We may compile or derive statistical information from your data to be aggregated with the statistical information compiled or derived from other visitors to the Website or users of the Service. However, such statistical information will be anonymous and non-identifiable to you. We aggregate statistical information to better serve its users and to improve the manner in which it conducts business.

Business Transfers: We may share your information in connection with a substantial corporate transaction such as a merger, consolidation, asset sale, or in the unlikely event of a bankruptcy.

IV. Sharing of Information

SRG will not sell, exchange, or transfer your information to any other company or third party, except (a) with your consent; (b) to provide and perform the Service requested; or (c) as required by law, regulation, legal process, an enforceable government request, to enforce any applicable Terms of Use (including investigating potential violations of this Privacy Policy), to detect, prevent, and address fraud or security issues, or to protect against harm to users or the general public. SRG may also use third parties to carry out certain services, such as website management and credit card processing. SRG only shares your information as necessary for these purposes.

Third-Party Services

SRG may include the use of partners or vendors to fulfill commitments as part of our Service and for the serving and/or targeting of ads, promotions, and other marketing messages. These ads may be provided by a third-party ad service provider. The ad service provider may place or utilize their own unique cookie on your browser and may use non-personally identifiable information about your visit to the Website, such as the number of times you have viewed the ad. SRG is not responsible for the collection of these cookies and is not responsible for the actions of the ad service providers. SRG does not sponsor, endorse, or guarantee any products or services advertised by third parties on its site.

External Links

SRG may place links to third-party websites not controlled or created by SRG. These websites may contain SRG brand names and trademarks and other intellectual property owned solely by SRG. When you click on these links and visit these third-party sites, regardless of whether or not they contain SRG brand names, trademarks, and other intellectual property, be aware that we do not control these other sites or their business practices and that this privacy policy does not apply to these other sites. We encourage you to review their privacy policies.

V. Your Personal Data Rights

You have the following rights concerning your information:

Opt out of marketing and promotional emails

You may opt out of receiving marketing or promotional emails at any time by clicking “Unsubscribe” at the bottom of the SRG email communication. If you have trouble opting out of SRG marketing or promotional emails, please email us at privacy@srg.com with the subject “STOP” and allow us a reasonable time to process your request.

California Consumer Privacy Act

California residents have a right to obtain certain information about the types of information companies collect, who they share that data with, why they collect it, which third parties have access to their data, and the right to elect not to have their data sold. To exercise your rights, please reach out to us through the email privacy@srg.com using the subject “CCPA” or mailing address listed at the bottom of this page under the Contact Information section. We may request additional information from you to verify your identity.

General Data Protection Regulation

If you are in the European Union, you have rights under data protection laws in relation to your personal data, including: (a) the right to be informed what information is processed, why, and who else may receive the information; (b) the right of access. This means you have the right to see what information is held about you by SRG; (c) the right to have your data corrected or amended if what is held is incorrect in some way; (d) the right to erasure. Under certain circumstances, you can ask for your personal information to be deleted. This applies where the personal information is no longer required for the purposes it was collected for, or your consent for the processing of that information has been withdrawn, or the information has been unlawfully processed; (e) the right to restrict processing, which gives you the right to ask for a temporary halt to processing of your information, such as in the case where a dispute or legal case in in progress or the information is being corrected; (f) the right to data portability, which is the right to ask for a copy of any personal information provided in a structured, commonly used, and machine-readable format; (g) the right to object to further processing of your personal information, which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing; and (h) the right to not be a subject to automated decision making and profiling. To exercise your rights, please reach out to us through the email privacy@srg.com using the subject “GDPR” or mailing address listed at the bottom of this page under the Contact Information section. We will respond to your request within 30 days. We may request additional information from you to verify your identity.

You have the right to lodge a complaint at any time about our processing of your personal data with your local data protection authority: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Children

SRG’s site and Services are not intended for use by any children under the age of 18. Nowhere on the Website do we knowingly collect contact information or financial information from children under the age of 18. If you are the parent or legal guardian of a child you believe may have submitted personal information to SRG, please contact us at privacy@srg.com or the mailing address listed at the bottom of this page under the Contact Information section.

Data Security, Data Transfer

SRG will store and process your information only as necessary to provide the Service requested. SRG has security measures in place to help protect against the loss, misuse, and alteration of the information under our control. We encrypt your contact information and financial information as it travels over the internet and we store this information in encrypted form. We also review our information collection, storage, and processing practices, including physical security measures, and restrict access to the information to SRG employees, contractors, and agents who need that information in order to process it according to the purposes disclosed in this Privacy Policy. Your information may be transferred to and maintained in whole or in part on computer networks, which may be located outside of the state, province, country, or other governmental jurisdiction in which you reside, and may be stored on equipment or in facilities leased or licensed from third parties. In the event of inquiries on compliance, we may request information to verify your identity and retain that information for legal safeguards. Unfortunately, no data transmission over the internet or any network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information and make reasonable efforts to do so. SRG cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. However, once we receive your transmission, we make our best effort to ensure its security on our systems.

Changes to the Privacy Policy

It is SRG’s policy to post any changes to the Privacy Policy on this page. The date the Privacy Policy was last revised is identified at the bottom of the page. You are deemed to have accepted such changes through your access to the Website or use of the Service after the date of such change. Please refer back to this Privacy Policy on a regular basis.

Contact Information

For questions about this Privacy Policy and SRG’s privacy practices, contact us at the email or mailing address listed below. Please keep in mind we may request additional information from you to verify your identity.

privacy@srg.com
Attn: Privacy
Sterling-Rice Group, Inc.
1801 13th Street, Suite 400
Boulder, CO 80302
USA

Last modified: October 17, 2019