Cookie & Privacy Policy

Last Updated: March 25, 2024

‍

1. Scope

‍

This Privacy Policy sets out how Stenn International Ltd and Stenn Assets USA Inc (each, respectively, “Stenn”, “we”, “our”, or “us”) collects, stores, processes, transfers, shares, and uses data that identifies or is associated with you when you use our website at https://stenn.com/ (the “Site”), our products and services, including Stenn’s Invoice Financing and Revenue-Based Financing Services (“Stenn Offerings”), tools, features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” mean you as the user of the Services, whether you are an existing or potential client (including a representative of a client), a Site visitor, or another individual whose personal data we have collected pursuant to this Privacy Policy.

‍

Please read this Privacy Policy carefully. If you do not agree to this Privacy Policy, please do not use or access the Services. The Services are intended for users aged 18 and older. We do not knowingly collect personal data from children, and, if we discover that we have inadvertently collected personal data from children, we will take commercially reasonable steps to delete that data. If you believe a child may have provided us with their personal data, please contact us using the details set out at the end of this Privacy Policy.

‍

‍

2. About Us

‍

If you are located outside of the U.S., then:

• Stenn International Ltd (company no. 09488169) is the data controller of the personal data we hold about you.
• We are registered as a data controller with the Information Commissioner’s Office under data protection registration number ZA182647.

If you are located within the U.S., then:

• Stenn Assets USA Inc (company no. 7254747) is the data controller of the personal data we hold about you.

‍

‍

3. Changes to this privacy policy

‍

We may update this Privacy Policy from time to time, so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the “Last Updated” date at the top of this Privacy Policy and take any other steps required by applicable law. Changes to this Privacy Policy are effective when they are posted on this page.

‍

‍

4. Personal data we collect about you

‍

The table at Annex 1 sets out the categories of personal data we collect about you and how we use that data. Where applicable, the table also lists the legal basis on which we rely to process the personal data. More generally, we collect personal data:

1. that you voluntarily submit to us, such as your contact details and identification information, when you use our Site or Stenn Offerings or otherwise interact with us by email, at online and physical events, or in the course of our business activities;
2. from third parties, such as background checking service providers, other financial institutions, social networks, public databases (where permitted by law), corporate websites, your business associates (including your buyers / suppliers), and other persons who may invite you to use our Services, and our partners where we carry out joint business activities; and
3. automatically, about how you access and use the Services and information about the device and browser you use to access the Services and our newsletters. We may link or combine the data we collect about you automatically, with other data we collect about you. This allows us to provide you with a personalised experience, regardless of how you interact with us.

Your provision of certain personal data is required in order for us to provide you with certain Services. If you choose not to provide such personal data, we may not be able to provide the Services you have requested.

‍

Please note that if you create your account on the Site or Stenn Offerings using your login details from Google, LinkedIn or other external platforms, you give permission to such external platforms to share with us your name, email address, language preference, and profile picture (if you have one).

‍

‍

5. Use of your data

‍

We use your personal data to provide you with our Services, including the Stenn Offerings. These include creating and maintaining your account, considering your application for financing, providing support, personalising our products and services to you, facilitating payments, and related account administration. We also process your data to correspond with you (including about your account, products, or services that may be of interest to you, and changes to our policies and terms), to perform our agreements (including with you or the organisation you represent), and to carry out marketing activities and day-to-day business activities and operations.

‍

We may also process your personal data for product research, development, and improvement. This includes testing our information technology systems, research, data and trend analysis, improving and developing our Site and the Stenn Offerings, and developing new products and features. This may involve processing data using artificial intelligence (AI) technologies, including generative AI tools provided by third parties. You may have the right to object to (i.e., opt-out of) your personal data being used for such purposes and can exercise this right by contacting us using the contact details included at the end of this Privacy Policy. Where practical or appropriate, we will deidentify your data for these purposes or other purposes permitted by applicable law. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified form and we will not attempt to re-identify the information, except to determine whether our deidentification processes satisfy legal requirements.

‍

Finally, we may process personal data to comply with our legal and regulatory responsibilities and policies, such as anti-money laundering, to enforce our terms and policies, to protect the Services, our rights, and the rights of our users or others, and for authentication, integrity and security purposes. For example, we may use your data to authenticate your account, identity, and activity, and to detect, investigate, and prevent suspected or actual fraudulent activity.

‍

‍

6. Disclosure of your data

‍

We may disclose personal data with the following recipients (in accordance with the uses set out in Annex 1):

• Vendors and service providers that perform services for us or on our behalf, or help us provide, improve, and market the Services. We share data with these third parties to perform our contract with you and in our legitimate interests to run a successful business. These services may include providing fraud prevention, background and anti-money laundering checks, identity verification, credit intelligence, client support, payment processing or account linking, technology or web hosting services. We may also use AI tools, including generative AI tools offered by third-party vendors and service providers (such as the Azure OpenAI Service).
• Business partners, such as trade credit providers, and institutional investors who purchase or provide credit. We share data with these third parties where this is necessary in the normal course of our business to perform our contract with you and to support the Stenn Offerings, or otherwise in our legitimate interests to run a successful business.
• Professional advisers, including auditors, law firms, or accounting firms, where necessary in the normal course of our business in our legitimate interests to protect our business or as required by law.
• Purchasers and third parties in connection with or anticipation of a business transaction, such as a merger, sale of assets or shares, reorganisation, financing, bankruptcy, change of control, or acquisition of all or a portion of our business. We share data with these third parties on the basis of our legitimate interests to run a successful business.
• Law enforcement, regulators, and other parties for legal or security reasons, as required by law or in our legitimate interests if we reasonably believe such action is necessary to: (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Stenn, its users, or others.
• Other members of the Stenn group (our affiliates), for example, where they provide services on our behalf, or where such sharing is otherwise necessary in the normal course of our business. We share data with these parties on the basis of our legitimate interests to run a successful business and effectively coordinate between members of the Stenn group.
• Parties you authorise, access, or authenticate, for example, when you request that we share certain data with third parties, such as your suppliers and buyers, or as otherwise necessary to effect a transaction initiated or authorised by you through our Services, on the basis of our legitimate interests to run a successful business or to perform our contract with you.
• Ad networks and advertising platforms to provide you with targeted advertisements or to conduct analytics, measurement and related services, on the basis of your consent (where required by applicable law).
• Marketing service providers to provide you with direct marketing on the basis of your consent (where required by applicable law) or, if permitted under applicable law, our legitimate interests in running a successful business.

‍

‍

7. Data retention

‍

We will store the personal data we collect about you for no longer than necessary for the purposes set out in Annex 1 in accordance with our legal obligations, to resolve disputes, collect fees owed to us, or otherwise in accordance with applicable law.

‍

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, as well as the applicable legal, regulatory, tax, accounting, or other requirements.

‍

‍

8. Data Security

‍

We implement certain technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change, or damage. However, despite our efforts to protect your data, no security measures are impenetrable, and we cannot guarantee “perfect security”. Any personal data you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential data.

‍

We will never send you unsolicited emails or contact you by phone requesting your account ID, password, or national identification numbers.

‍

‍

9. Where we store your personal data

‍

Your personal data may be transferred or processed outside of the UK and European Economic Area (“EEA”), including to countries that do not offer the same level of protection such as the US. International transfers will be made pursuant to appropriate safeguards, such as the standard contractual clauses adopted by the European Commission or the UK-equivalent terms. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this Privacy Policy.

‍

‍

10. U.S. Residents

‍

This section applies if you are a resident of California or another U.S. state that has passed a privacy law similar to the California Consumer Privacy Act (“CCPA”) and requires specific privacy policy disclosures. For purposes of this section and Annex 1, references to “personal information” and “personal data” shall also include “sensitive personal information” as those terms are defined under the CCPA.

‍

Our Collection, Use, and Disclosure of your Personal Information

‍

The table in Annex 1 sets out the categories of personal information (including sensitive personal information, denoted by *) we collect and disclose (if applicable), including over the past 12 months.

‍

For information regarding the specific purposes for which we collect and disclose your information, and the categories of sources from which we collect such information, please see the sections above, Personal Data We Collect About You, Use of Your Data, and Disclosure of Your Data. Information about our retention of personal information is described above in Data Retention. We use and disclose sensitive personal information only for the purposes specified in the CCPA or otherwise in line with your consent.

Personal Information Sales and Sharing

We do not have actual knowledge that we “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information of individuals under 16 years of age. However, as described in our Cookie Policy, we have incorporated cookies from certain third parties into our Services. These cookies allow third parties to receive information about your activity on our Services that is associated with your browser or device, and those third parties may use the information for advertising, retargeting, and marketing purposes, including to serve you ads about Stenn on other websites or platforms you visit, as described further in section 13 below. Under the CCPA, our disclosure of your personal information through third-party cookies may qualify as a sale or sharing of personal information.

‍

We share, and, in the preceding 12 months, have shared, the following categories of personal information with third parties for such purposes:

‍

‍

‍

For information on how to opt-out of such sharing, please see the section immediately below.

‍

‍

11. Your rights in respect of your personal data

‍

In accordance with applicable privacy law, you may have the following rights in respect of your personal data that we hold:

‍

(a) Right to Access / Know. The right to request access to your personal data, including details relating to the ways in which we use and share your personal data, or the ways in which your personal data has or may have been used or disclosed by us in the past.

‍

(b) Right to Rectification / Correct. The right to request that we rectify / correct any inaccurate or incomplete personal data we hold about you.

‍

(c) Right to Erasure / Deletion. The right to request that we erase your personal data.

‍

(d) Right of Portability. The right to request a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

‍

(e) Right to Restriction. The right to ask us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

‍

(f) Right to Object. The right to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive. Unsubscribing from marketing communications will not unsubscribe you from system notifications that we need to send as part of the Service we provide. From time to time, we may need to contact you by email or via our support team.

‍

(g) Right to Withdraw Consent. If you have provided consent to any processing of your personal data, you may have a right to withdraw that consent at any time.

‍

(h) Right to Opt-Out of Selling/Sharing. The right to direct us not to sell or share your personal data to third parties. To exercise this right, please contact us at privacy@stenn.com. For information on how we process opt-out preference signals, see our Cookie Policy at Annex 2.

‍

(i) Right to Opt-Out of Targeted Advertising. The right to opt-out of the processing of your personal data for targeted advertising. See section 13 of this Privacy Policy and our Cookie Policy for further information.

1. Please note the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
2. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy. You may also review and edit some of the personal data you have submitted to us by logging into your account on our website.
3. We will not discriminate against you for exercising your rights. We may need to request additional information from you to verify your identity before honouring a rights request, such as your email address or government-issued ID. You may designate, in writing or through a power of attorney document, an authorised agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorised them to act on your behalf, and we may need you to verify your identity directly with us. If we deny your request, you may appeal our decision by contacting us using the contact details at the end of this Privacy Policy.

If you think we have infringed applicable data protection laws, you can file a claim with the data protection supervisory authority in the country in which you live or work, or where you think we have infringed such laws. For information on how to contact the UK Information Commissioner Officer, please access www.ico.org.uk, and, for information on how to contact data protection authorities in the EEA, please access http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

‍

‍

12. Cookies and similar technologies

‍

Our website uses cookies and similar technologies (“cookies”) to distinguish you from other users of our website. Please refer to our Cookie Policy at Annex 2 for more information about the way in which we use cookies on our Site.

‍

‍

13. Interest-based advertising

‍

We participate in interest-based advertising, and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect data about how you use or connect to our Site, or the types of other websites, social media services, content, and ads that you (or others using your device) visit or view, or connect to our Site so that we or our advertising partners may play or display ads on our Site, on other websites, apps, or services you may use, and on other devices you may use.

‍

Typically, but not always, this data is collected through cookies. We and our third-party partners use this data to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services, such as reporting, attribution, analytics, and market research. Please refer to our Cookie Policy at Annex 2 for more information about the way in which we use cookies on our Site.

‍

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising and limit some third-party advertising cookies, you may wish to visit:

• Your Online Choices (http://www.youronlinechoices.com/)
• Network Advertising Initiative (“NAI”) (http://www.networkadvertising.org/)
• Digital Advertising Alliance (“DAA”) (http://www.aboutads.info/consumers)

Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each browser or device you use.

‍

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

‍

‍

14. Links to third-party sites

‍

Our Site may, from time to time, contain links to and from third-party websites, including those of our business partners, advertisers, news publications, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

‍

‍

15. Notice to you

‍

If we need to provide you with information about something, whether for legal, marketing, or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Site. The fact that we may send notices to you will not stop you from being able to opt-out of certain types of contact, as described in this Privacy Policy.

‍

‍

16. Contacting us

‍

If you have any questions, comments, and requests regarding this Privacy Policy, you can contact us at privacy@stenn.com.

‍

‍

Annex 1 - Personal data we collect

‍

The table below sets out the categories of personal data (including sensitive information under U.S. law, denoted by *) we collect and disclose, including over the past 12 months.

‍

‍

‍

Where we rely on contractual necessity or where we process your personal data subject to a legal obligation, and you fail to provide your personal data to us, we may not be able to provide our Services to you.

‍

‍

‍

Annex 2 - Stenn cookie policy

‍

‍

Last Updated: March 25, 2024

‍

We use cookies and similar technologies (“cookies”) to offer our Services to you.

‍

‍

1. What are cookies?

‍

Cookies are small text files, placed on a computer hard drive, that can uniquely identify a particular browser or device. They are widely used to make websites work more efficiently for visitors and to provide website owners with traffic information. Similar technologies include pixels (small portions of code used to learn whether you have clicked on web content), web beacons (invisible picture files used to see how you interact with and view certain content), mobile device IDs (unique identifier which can be used to identify a mobile device), local storage (which is used to store data on your device such as the last time you visited a webpage) and HTML5 storage (which allows information to be stored in your browser after the browser has been closed and reopened). Cookies allow the server to deliver personalised pages for users, as cookies remember your preferences and make the interaction between you and our Services smoother and more efficient. When users access our Services, the browser retrieves their previous activity. This allows the browser to keep the user logged in and many other functions that make the navigation more effective.

‍

We may also use cookies in some of the emails we send you. These enable us to understand whether you have opened the email and how you have interacted with it. If you have enabled images, cookies will be set on your device and will also be set if you click on any link within the email.

‍

Without cookies, we may not be able to provide certain services or features, and our Services will not work as efficiently as intended. You can turn off cookies, but if you do this, you may not be able to access all of our Services.

‍

‍

2. Setting and storing cookies

‍

Cookies may be set either by the website you are visiting (“first-party cookies”) or by third-party websites that run content on the website you are viewing (“third-party cookies”).

‍

‍

3. Different types of cookies

‍

We and our partners (including Google, Salesforce, LinkedIn, Hotjar, Microsoft, Heap Analytics, Adobe, and Reddit) use the following types of cookies:

• Essential cookies: These cookies are essential to enable you to login, navigate around and use the features of a website, or to provide a service requested by you. We do not need to obtain your consent in order to use these cookies.

• We use strictly necessary cookies for purposes including showing you our cookie banner when you first access our Services and remembering your decision to accept or decline non-strictly necessary cookies—such cookies will remember your settings for up to a year. When you login to the Stenn Offerings, we use strictly necessary session cookies to remember that you have logged in when you navigate from page to page. We deploy various first party strictly necessary cookies to help protect the security of our Services, including to identify malicious users and to detect and prevent spam, fraud and abuse, such cookies could last for up to six months. 

• Functionality cookies: These cookies allow a website to remember choices you make (such as username, language, or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located. The information these cookies collect cannot track your browsing activity on other websites.

• We use functionality cookies to remember the choices you make with respect to our Services, including your preferred language settings for each session, which last for the duration of your session. 

• Performance cookies: These cookies collect information about your online activity, for example, which website pages you go to most often, difficulties you may experience while using the website for example, error messages) and your interactions with emails. They allow us to provide you with a better user experience and to maintain, operate and continually improve the Services.

• We and our partners use performance cookies to analyze your use of our Services, including to identify and distinguish different users, and to help us understand how you use the Services (e.g., how much time you spend on which pages on our Site, the time it takes for the page to load, which links you choose to click, the percentage of the page you view, whether you are a previous user of our Site and how much time has passed since your last visit). Such cookies can last for the duration of your session or for up to one year.

• Targeting cookies or advertising cookies: These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement, as well as to help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations, such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

• We and our partners use targeting and advertising cookies to deliver tailored advertisements to you. For example, these cookies are used for identifying unique users and collecting information about your interactions with our Services in order to display ads relevant to you, as well as registering and reporting your actions after clicking or viewing an ad in order to measure the efficiency of the ad. Such cookies can last for the duration of your session or for up to one year.

• Social media cookies: These cookies enable us or the social network to obtain information about how you interact with our Services or the social network. In addition, where we have a presence on social media platforms, those platforms will set cookies on your device when you visit our pages on their platforms so that we can obtain statistical information about how you interact with our social media presence. The cookies policy of the social media platform should explain how you can manage the cookies that they set or you may also be able to manage these cookies by using your browser settings, as explained below.

• Our Services include social media features, such as links to our social media profiles. These features are either hosted by a third party or hosted directly on our Services (in which case, you can manage them as explained below). For example, these cookies may be used to track views of embedded content (such as videos) or advertisements so that similar content and advertisements can be recommended to you. Such cookies can last for the duration of your session or for up to one year.

As described above, we use a number of third-party cookies. For example, we use Google Analytics, a web analytics tool that helps us understand how users engage with our Services. Like many providers, Google Analytics tracks user interactions on our Services. This information is used to compile reports and to help us improve our Services. The reports disclose trends on our Services without identifying individual visitors. For more information on Google Analytics, see here. You can opt-out of Google Analytics tracking by visiting https://tools.google.com/dlpage/gaoptout.

‍

We also use Hotjar to better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.), and this enables us to build and maintain the Services with user feedback. Hotjar uses cookies and other technologies to collect this information, and stores this information on our behalf in a pseudonymised user profile. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

‍

‍

4. Consent to use cookies

‍

We will ask for your consent to place cookies or other similar tracking technologies on your device, except where these are essential for us to provide you with a service you have requested. There is a banner notice on our home page that describes how we use cookies and requests your consent before we place any non-essential cookies on your device.

‍

‍

5. How to manage your cookie settings

‍

Adjusting your cookie preferences

There are various ways in which you can manage and control your cookie settings. You may allow or reject the use of non-essential cookies when using our Services by changing your cookie preferences [here]. You can also access your cookie preference settings from the footer of each page, by clicking the link.

‍

Please note that, by deleting or blocking cookies, some or all of the websites you visit (or features of them) may not work properly or as effectively.

‍

To find out more about cookies, including how to see which cookies have been set and how to manage and delete them, you can visit the third-party website: www.allaboutcookies.org.

‍

Turning off cookies via your web browser

In addition, adjusting your cookie preferences as per the above, most modern web browsers will provide you with some general information about cookies, enable you to see what cookies you have, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third-party advertising cookies separately.

‍

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. Our Services recognise the Global Privacy Control (GPC) signal, which enables you to opt-out of certain uses or disclosures of your information. If you notify us of your preference through GPC, we will honour your request only for the browser or device that sends the GPC signal. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.

‍

Please note that if you adjust your cookie settings via your web browser then, unless you delete or block each cookie individually, the changes will apply to all websites that you visit – not just our Services. You will also need to adjust your cookies on a browser-by-browser basis.

‍

‍

6. Updates to this Cookie Policy

‍

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons.

‍

The date at the top of this Cookie Policy indicates when it was last updated.

‍

‍

7. Contact us

‍

If you have any questions or comments about this cookie policy, or privacy matters generally, please contact us at privacy@stenn.com.

‍

‍