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PRIVACY POLICY

Last updated July 21, 2018    


Thank you for choosing to leverage the STP Investment Service, LLC Portal for your data aggregation and reporting needs. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@stpis.com.

When you visit our STP Portal (https://stpis.com), and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please contact us using the provided contact information below.

This privacy policy applies to all information collected through our production and UAT portals (https://stpis.com, https://portaltest.stpis.com), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Portal"). 

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  


TABLE OF CONTENTS  

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH 3RD PARTIES?    

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?        

5. WHAT IS THE STP RETENTION PERIOD FOR YOUR DATA?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?    

7. DO WE COLLECT INFORMATION FROM MINORS?  

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

10. DO WE MAKE UPDATES TO THIS POLICY?

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?


1. WHAT INFORMATION DO WE COLLECT?  

 

Personal information you disclose to us 

Summary:  We collect personal information that you provide to us such as name, phone number and password information. Please note all data housed in STP data centers is encrypted at rest in the storage array.    

We collect personal information that you or a representative at your firm provides to us in the new user setup process.

Name and Contact Data. We collect your first and last name, email address, username and phone number information.

Credentials. We collect username and passwords for authentication and account access. The STP Portal monitors all login activity to ensure a secure environment.

Payment Data.The STP Portal does not collect or store any payment or credit card information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.  

Information collected from other sources 

Summary:  We do not collect any data from public databases, marketing partners, and other outside sources.     

The only information stored about an individual is referenced above in the "personal information we disclose" section.


2. HOW DO WE USE YOUR INFORMATION?  

Summary: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.  

We use personal information collected via our Portal for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.   

We use the information we collect or receive:    

  • To facilitate account creation and logon process The logon information associated to your account drives the logic for the Portal's security framework and enforces entity and feature level permissioning.                       

  • To protect our Portal   for Business Purposes and/or for Legal Reasons . We may use your information as part of our efforts to keep our Portal safe and secure (for example, for fraud monitoring and prevention).                                                    


3. WILL YOUR INFORMATION BE SHARED WITH 3RD PARTIES?  

Summary: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.   

We only share and disclose your information in the following situations: 

  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 

  • Vital Interests and Legal Rights.  We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.       

  • Business Transfers.  We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.           

  • With your Consent.  We may disclose your personal information for any other purpose with your consent.      


4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?  

Summary:  We do not use cookies and other tracking technologies to collect and store your information.  

We do not use cookies to access or store your personal information. The only cookie the Portal stores is a unique id to track a user's session. This cookie does not contain any private and/or personal information about the logged in user.      


5. WHAT IS THE STP RETENTION PERIOD FOR YOUR DATA?  

Summary: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.  

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years past the termination of the user's account .  

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


6. HOW DO WE KEEP YOUR INFORMATION SAFE?   

Summary: We aim to protect your personal information through a system of organizational and technical security measures.  

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Portal is at your own risk. You should only access the services within a secure environment.  


7. DO WE COLLECT INFORMATION FROM MINORS?  

Summary: We do not knowingly collect data from or market to children under 18 years of age.  

We do not knowingly solicit data from or market to children under 18 years of age. By using the Portal, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Portal. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@stpis.com.    


8. WHAT ARE YOUR PRIVACY RIGHTS?  

Summary:  You may review, change, or terminate your account at any time.    

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm 
 

Account Information  

If you would at any time like to review or change the information in your account or terminate your account, you can:    

■   Log into your account settings and update your user account.    

■   Contact us using the contact information provided.    

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.          

Cookies and similar technologies:  Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Portal.

Opting out of email marketing:  You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:    

■   Contact us using the contact information provided.    


9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?  

Summary: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.   

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with the Portal, you have the right to request removal of unwanted data that you publicly post on the Portal. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Portal, but please be aware that the data may not be completely or comprehensively removed from our systems.


10. DO WE MAKE UPDATES TO THIS POLICY?  

Summary: Yes, we will update this policy as necessary to stay compliant with relevant laws.  

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 


11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?  

If you have questions or comments about this policy, you may email us at info@stpis.com or by post to:

STP Investment Service, LLC         
158 W. Gay St.    
STE 300    
West Chester, PA 19380        
United States