Website Privacy & Security Statement ("Privacy Policy")

GENERAL

Thank you for visiting the Stelac Advisory Services website. This website is operated by Stelac Advisory Services LLC ("we", "us", "our", "ours", "Stelac"). This policy applies only to personal information that is received through our website. This Policy applies only to the use of our website by the general public. This policy does not concern the processing of client data by Stelac.

We will treat your personal information received through our website in accordance with this Policy and applicable law. Stelac is the entity which is responsible for the control and processing of personal data that we collect from you when you use this Website. If you have any questions or concerns about Stelac’s use of your personal data, please contact us at compliance@stelac.com.

WHAT IS "PERSONAL INFORMATION"?

In general, your personal information means information that relates to you and by which you, as an individual, can be identified. It includes identifiers such as your name, mailing address, telephone number, and e-mail address and any information that we collect about you.

This Privacy Policy relates to your personal data (i.e., data about you, an individual, from which you can be identified).

This Privacy Policy therefore does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to a living individual (such as anonymized data or aggregated data which, in a given form, cannot directly or indirectly be used to identify you as an individual) ("Anonymized and Aggregated Data"). We reserve the right to generate Anonymised and Aggregated Data extracted out of any databases containing your personal data and to make use of any such Anonymised and Aggregated Data as we see fit (including publishing such data and sharing it with third parties).

INFORMATION WE COLLECT

We do not currently collect personal information through this website except for information that (a) your Internet service provider automatically provides to our web server, and (b) you send to us in an e-mail message using the e-mail facility that is part of this website's functionality.

INFORMATION COLLECTED AUTOMATICALLY

We automatically collect and store only the following information about your visit:

The Internet domain, the IP address that is automatically assigned to your computer whenever you are surfing the Web from which you access our web site; the type of browser and operating system used to access our site; the date and time you access our site; the pages you visit and how long you visited each page; and if you linked to our web site from another web site, the address of that web site..

COOKIES

This Website will place a small data file, known as a "cookie," on your hard drive. Cookies are used to track your use of the Website and to identify you throughout your browsing. This enables the collection of data referred to above. You can choose to not receive a cookie file by enabling your web browser to refuse cookies or to prompt you before you accept a cookie. If you do that, the full functionality of this Website may not be available to you.

DO NOT TRACK

We honor Do Not Track signals and do not track, plant cookies or use advertising when a DNT browser mechanism is in place,

HOW WE USE PERSONAL INFORMATION

We may use personal information collected from this Website to respond to your email requests and to monitor, personalize and improve the performance and content of the Website. Data collected automatically through the Website may be used for our internal business purposes, such as compiling and analyzing usage information of our Website, for general operational, statistical and business purposes.

DISCLOSURE TO THIRD PARTIES

We may use third parties to provide data processing, hosting, storage, emergency recovery services, and similar services to us. It may be necessary for these third parties to have access to personal information you have provided on this Website or which was automatically collected through the Website. Where your information is shared with such third parties, we ensure that the third party service provider will deal with your information only on our behalf and on our written instructions and solely for our benefit.

If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer databases containing the data collected automatically by the Website in connection with such transaction or change in ownership or legal structure.

To the extent permitted or required by applicable law, we may disclose information about you to third parties to: (i) enforce or apply the terms and conditions of our services; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our users or others; violation of our policies or agreements; or as otherwise required by law.

We will not otherwise disclose your personal information to third parties, unless required or permitted to do so by law or unless you consent.

As mentioned above, we may also aggregate or otherwise strip information of all personally identifying characteristics and may share that Anonymized and Aggregated Data with third parties or publish it.  This Anonymized and Aggregated Data does not personally identify you and helps us to measure the success of the Website and its features and to improve your experience.  We reserve the right to make use of any such Anonymized and Aggregated Data in our sole discretion.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

SECURITY

We use physical, electronic and procedural safeguards to protect your personal information. We do not guarantee that our safeguards will always work. Information sent to us using this website may not be secure in transmission.

THIRD PARTY SITES AND SERVICES

The Website may reference or provide links to other sites, applications, or resources. If you access any website, application, or resources provided by a third party, our Privacy Policy will not apply. Your interactions with such websites, applications, and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.

CHILDREN’S DATA

Our business offerings are not directed to children and our Website is intended for use by adults only. We do not knowingly collect personal data from individuals under 18 years of age. If you are under the age of 18 please do not submit any personal information to us.

CALIFORNIA PRIVACY RIGHTS

Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of information to third parties for the third parties' direct marketing purposes. To make such a request, please send an email to compliance@stelac.com with "Request for California Privacy information" in the subject line. You may make such a request up to once per calendar year. If applicable, We will provide to you via email a list of the categories of information disclosed to third parties for their direct marketing purposes during the immediately-preceding calendar year, along with the third parties' names and addresses. Please note that not all personal data sharing is covered by the requirements of California Civil Code Section 1798.83.

EU PRIVACY RIGHTS

Users based in the European Union have the following legal rights in respect of their personal information:

a)    The right to require Stelac to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;

b)    The right to require Stelac to rectify inaccurate information without undue delay;

c)    Where Stelac has relied on the ‘consent’ basis for processing that information (see ‘Legal Basis for Processing Your Information’ above), the right to withdraw their consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal;

d)    The right to request the erasure of their information in certain circumstances. You can make a request for erasure where:

                   (i)        the information is no longer necessary in relation to the purpose for which it was collected;

                  (ii)        where the processing of the information is based on the user’s consent (and the other circumstances described in the ‘Legal Basis for Processing Your information’ and ‘Disclosure to Third Parties’ sections above no longer apply), if the user withdraws his or her consent; or

                (iii)        where the personal data is processed by Stelac solely on the basis of our ‘legitimate interest’ referred to in ‘Legal Basis for Processing Your Information’ above (and the other legal basis set out in that section do not apply), if the user objects to the processing of his or her personal data and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defence of legal claims).

Where Stelac has disclosed the information of a European Union user to a third party and the user requests the erasure or rectification of the data, Stelac will take all reasonable steps to inform the third party of such request;

e)    The right to require Stelac to restrict its processing of a user’s personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, Stelac will only process that information with the express consent of the user, or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;

f)     Where data is processed based on user’s consent or to fulfil a contractual obligation, the user has the right to receive his or her personal data from Stelac in a structured, commonly used and machine-readable format;

g)    The right to object to the processing of personal data where:

                 (iv)        Stelac relies solely on the ‘legitimate interest’ basis for processing that data, in which case we will be legally required to stop processing the user’s information unless we have compelling legitimate grounds for the processing which override the user’s privacy rights and interests; or

                  (v)        the information is used for direct marketing purposes, in which case we will immediately stop processing the user’s information for such purposes;

h)    Users have the right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides.

The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment. Where the records of data held by a controller do not enable it to identify specific individuals, the European Union laws do not require that the controller should undertake further processing in order to respond to any of the above rights.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

Insofar as it concerns the data of individuals in the European Union, we rely on the following lawful basis for the processing of your personal data:

a)    Our legitimate interests in (among other things) delivering the Website, improving and maintaining the Website, personalizing and tailoring content made available to you through the Website, maintaining records of correspondence  and responding to correspondence we receive through the Website, protecting the security or integrity of our databases, protecting our business or reputation, taking precautions against legal liability, dealing with our assets in the event of a business change (see further below), protecting and defending our legal rights or property, or for resolving disputes, investigating and attending to inquiries or complaints with respect to your use of the Website;

b)    Where relevant, your express consent, which you are free to withdraw at any time by way of email to compliance@stelac.com;

c)    Where relevant, for compliance with legal obligations to which we are subject.

COUNTRY OF PROCESSING

We carry out our business from the United States of America (USA) and our data collection and processing activities take place predominantly in the USA. We may store and otherwise process data (including personal data) through third party service providers which may be located or which may operate in other countries.

AMENDMENT

We reserve the right to amend this Policy from time to time and your continuing use of this Website constitutes your acceptance of any modification to this Policy as in effect at the time of your access. Any changes take effect upon posting to this website.

DISCLAIMER

This communication, including any attachments, is for informational purposes only. It is not intended as an offer or solicitation for the purchase or sale of any financial instrument or as an official confirmation of any transaction.

All market prices, data and other information are not warranted as to completeness or accuracy and are subject to change without notice. This transmission may contain information that is privileged, confidential, and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is strictly prohibited.

If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format. Thank you.

HOW TO CONTACT US

If you have any questions about this Policy or our use of your personal information, please email us at compliance@stelac.com.