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 Personal 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”), when you apply for a job with us, and also provided to us by third parties. It also describes SRG’s practices for collecting, using, maintaining, protecting, and disclosing your Personal Information.

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. 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. Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

Identifiers, such as your name, physical address, email address, telephone number, account name, and device identifiers.
Protected class and demographic information, such as age, sex, gender, disability, marital status, veteran status, race, and ethnicity.
Commercial information, such as information about purchases or quotes, information about subscriptions, products and services you have shown interest in, and other commercial information.
Device information, consisting of information from devices you connect to or use with our website, including your mobile device, connected devices, and wired and wireless sensors. The information we receive from these devices may include IP address and similar unique device identifiers.
Internet or other electronic network activity information, such as browsing history, search history, device and browser information, and information about your interactions with and use of our products, services, and social media.
Geolocation data, such as from devices you connect to or use with our products and services, including your mobile device, connected devices, and wired and wireless sensors, such as through the use of geolocation features in the devices, or by inference from other information we collect (for example, your IP address may indicate the general geographic region from which you are connecting to the Internet).
Professional or employment-related information, such as your job title, employer, and income.
Inferences drawn from the information we collect about you to create a profile about you reflecting your preferences.

When you apply for a job with us, we also collect Personal Information, which may include:

Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
Information from interviews you may have, if any;
Details of the type of employment you are looking for, current and/or desired salary and other terms relating to compensation and benefits packages, and job preferences;
Details of how you heard about the position you are applying for;
Any sensitive and/or demographic information obtained during the hiring process such as Social Security number, gender, information about your citizenship and/or nationality, medical or health information, and/or your racial or ethnic origin;
Reference information and/or information received from background checks (as applicable), including information provided by third parties;
Information relating to any previous applications you may have submitted to SRG and/or any previous employment history with SRG; and
Information about your educational and professional background from publicly available sources that we believe is relevant to your application or a potential future application (e.g., your LinkedIn profile).

III. How We Collect Your Personal Information

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.

Personal Information From Third Parties. For example, we may work with business partners, national database resources, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information.

Personal Information Collected Through Online Tracking Technologies

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

Your browser type and operating system;
Your email and Internet Protocol (IP) address;
Sites you visited before and after visiting the Website;
Date and time of your visit;
Webpages and advertisements you view and links you click on within the Website;
Unique identifiers for your device, operating system, and mobile network, including carrier name and phone number, and application version number;
Information collected through cookies, web beacons, Google Analytics, and other technologies;
Information about your interactions with email messages, such as the links clicked on and whether messages were opened or forwarded;
Standard server log information; and
Service-related data.

When you use the Service and Website, information collected through certain technologies may include or be combined with Personal Information to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in. Methods may include

Google Analytics

SRG uses analytics services, including Google Analytics on our Website, to assist us with analyzing our website traffic through cookies and similar technologies. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses information from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit How Google Uses Cookies.

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.

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.

Your Choices

You can disable cookies and other similar technologies on your computer by indicating this in the preferences or options menus in your browser or consulting the Help section of your specific browser, and your mobile device may allow you to disable transmission of unique identifiers and location data. You can also use our cookie preference page to decide which of the above technologies you wish to enable when you use our Website. Disabling cookies or blocking device identifiers may prevent some features of the Website from being available, or some functionality may be limited or unavailable. You can learn more about cookies and how to manage them at https://www.allaboutcookies.org/.

IV. How We Use the Personal Information Collected

To the extent permitted by applicable law, we may use Personal Information:

To operate the Website and provide support to our business functions;
To respond to questions about the Website, Service, or other general inquires;
To deliver the services you have requested and to perform quality assurance, sales analyses, and other business analyses;
To personalize your pages, optimize your experience of the Website and Service;
To identify problems and observe usage trends, such as time spent on page, path taken, key words used to find the Website and number of visits;
To tailor advertisements and communications to the appropriate audience;
To send marketing and promotional materials, including newsletters providing you with additional information on how to use the Services and promotional offers for goods and services from SRG or third parties;
To prepare and send invoices, make and receive payments, and manage client accounts;
To protect against criminal activity, claims and other liabilities;
To operate the Site and provide support to our business functions;
To fulfill customer requests and provide customer support;
To protect the security and integrity of the Site;
To the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Site, facilitating product, software and applications development, improving the Site or our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
To meet our contractual requirements;
To comply with applicable legal or regulatory requirements and our policies;
To market, advertise, and provide the Site and our services;
To protect users and help improve the safety and reliability of the Website and prevent potentially illegal or prohibited activities; and
To the extent necessary for any other lawful purpose for which the Personal Information is collected.

V. Sharing of Personal Information

We may disclose your Personal Information in the following circumstances:

Service Providers

When we hire a service provider to help operate the Website or offer our Services, we may give access to Personal Information as necessary to perform such services. This may include third parties who carry out certain services, such as website management, send our communications, manage our customer relations, and credit card processing. SRG only shares your information as necessary for these purposes.

Third-Party Services for Marketing Purposes

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 are not responsible for the practices employed by any websites or services linked to or from the Website, including the information or content contained within them. We encourage you to review their privacy policies.

For Legal Obligation or Safety Reasons

When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of SRG, its users, or the public against harm.

In the Case of a Merger or Sale

We may share your Personal Information in connection with a substantial corporate transaction such as a merger, consolidation, asset sale, or in the unlikely event of a bankruptcy. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.

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.

Affiliates

We may share Personal information with our affiliated companies.

VI. How Long Do We Keep Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Policy, or any longer retention period required by law.

VII. Your Personal Information Rights

Depending on where you live, you may have the right to exercise certain controls and choices regarding our collection, use, and sharing of your Personal Information. These rights may include the right to access, delete, limit use of, and correct Personal Information, as well as the right to opt out of automated decision making. Please contact us using the information in Section IX below for more 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.

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our services to you.

Children’s Privacy

SRG’s Website 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. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. 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

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. 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.

VIII. Individuals in the EU or UK

If you are in the European Union or United Kingdom, you may have rights under data protection laws in relation to your personal data, including: (a) the right to be informed what Personal Information is processed, why, and who else may receive or have access to it; (b) the right to receive a copy of your Personal Information; (c) the right to have your Personal Information corrected or amended if what is held is incorrect in some way; (d) the right to ask for your Personal Information to be deleted; (e) the right to restrict processing; (f) the right to data portability; (g) the right to object to further processing of your Personal Information; and (h) the right to not be a subject to automated decision making and profiling. To exercise your rights, please reach out to us at 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.

We process your Personal Information for a variety of legal purposes, including (i) where it is necessary in connection with our performance of a contract with you, (b) in connection with our legitimate business interests, or (iii) with your consent.

You have the right to lodge a complaint at any time about our processing of your Personal Information with your local data protection authority. If you are in the European Union you can find details at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm, and if you are in the United Kingdom you can contact www.ico.org.uk.

IX. California Residents

This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CPRA”). This Section describes (1) the categories of Personal Information collected and disclosed by us, subject to CPRA, (2) your privacy rights under CPRA, and (3) how to exercise your rights.

When we use the term “Personal Information” in the context of the CPRA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided below.

A. Categories of Personal Information Collected, Used, and Shared

We have collected the following categories of Personal Information from our consumers within the last 12 months. The sources from which we obtain this information and the ways in which we use this information are set forth in Section II above. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Category	Collected	Category of Source from which Personal Information is Collected	Third Parties to whom Personal Information is Disclosed for a Business Purpose	Third Parties to whom Personal Information is Disclosed for a Business Purpose	Third Parties to whom Personal Information is Sold or Shared
Identifiers.	Yes	Directly from you	See section above titled “How We Use the Personal Information Collected”	Service providers.	We do not sell this category of Personal Information. However, we share this category of information with third parties for purposes of cross-context behavioral advertising.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Yes	Directly from you	See section above titled “How We Use the Personal Information Collected”	Service providers.	We do not sell or share this category of Personal Information.
Protected classification characteristics under California or federal law.	Yes	Directly from you	See section above titled “How We Use the Personal Information Collected”	Service providers.	We do not sell or share this category of Personal Information.
Commercial information.	Yes	Directly from you; Third parties	See section above titled “How We Use the Personal Information Collected”	Service providers.	We do not sell or share this category of Personal Information.
Biometric information.	No	N/A	N/A	N/A	N/A
Internet or other similar network activity.	Yes	Directly from you; Third parties; Cookies and other tracking technologies	See section above titled “How We Use the Personal Information Collected”	Service providers.	We do not sell this category of Personal Information. However, we share this category of information with third parties for purposes of cross-context behavioral advertising.
Geolocation data.	Yes	Third parties; Cookies and other tracking technologies	See section above titled “How We Use the Personal Information Collected”	Service providers.	We do not sell or share this category of Personal Information.
Sensory data	No	N/A	N/A	N/A	N/A
Professional or employment-related information.	Yes	Directly from you; Third parties	See section above titled “How We Use the Personal Information Collected”	Service providers.	We do not sell or share this category of Personal Information.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	No	N/A	N/A	N/A	N/A
Inferences drawn from other personal information.	Yes	Internally derived	To conduct analytics, business and product development	Service providers.	We do not sell or share this category of Personal Information.

We share each of these categories of Personal Information with our service providers to the extent necessary for them to facilitate our business purposes. We also share this Personal Information for the purposes set forth in Section IV above.

We will retain your Personal Information for as long as we need it to provide you with our Services. Because the length of your use of our services are not foreseeable, we cannot provide you with an exact timeframe for how long we retain your information. Our legal obligations may also require us to maintain your Personal Information for longer periods of time if your Personal Information becomes subject to such legal obligations.

B. Your California Privacy Rights

Subject to certain exceptions, if you are a resident of California, you may have the following rights:

Privacy Right	Description
Notice	The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access	The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability	The right to receive the Personal Information you have previously provided to us.
Erasure	The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
Correction	You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
Automated Decision Making	You have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out. SRG does not currently engage in any automated decision making practices.
To Opt Out of Sales or Sharing of Personal Information	You have the right to opt-out of the sale and sharing of your Personal Information by clicking the “Do Not Sell or Share My Personal Information” link on the footer of our Site. When you opt-out of sales, we will stop selling your Personal Information to third parties. When you opt out of sharing, we will not share your Personal Information with third parties for purposes of cross-context behavioral advertising.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Other California Privacy Rights

California Civil Code Section 1798.83 permits visitors to our site who are California residents and who have an existing business relationship with us to request certain information regarding our disclosure of personal information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please send an email with the subject heading “California Privacy Rights” to us at privacy@srg.com, or you may write to us at the address below.

X. Exercising Your Individual Privacy Rights

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Policy which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

To exercise your privacy rights under applicable data protection law, please submit a request to us by one of the following methods:

Calling us toll free at 800-488-6311
E-mailing us at privacy@srg.com

Verification: We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes.

Appeals: If you are not satisfied with the resolution of your request and would like to submit an appeal, please email us at privacy@srg.com.

XI. 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. We may provide you with an updated Privacy Policy if material changes are made, if required by law. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Site. Please refer back to this Privacy Policy on a regular basis.

XII. 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 150
Boulder, CO 80302
USA

Last modified: March 6, 2023