Stenn International ltd
Privacy policy
Stenn International Ltd ("Stenn", "we", "our", or "us") is committed to protecting and respecting your privacy.
Our approach to privacy
This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you use our website at https://stenn.com/ (the "Site"), use our services or otherwise interact with us.
About us
Stenn International Ltd (company no. 09488169) is the data controller of the personal information we hold about you.
Our registered and postal address is V 101 1-45 Durham Street, London, England, SE11 5JH.
We are registered as a data controller with the Information Commissioner’s Office under data protection registration number ZA182647.
Personal information we collect about you and how we use it
The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
More generally, we:
- collect personal information that you voluntarily submit to us, such as your contact details and identification information, when you use our Site or our invoice financing services, act as a Stenn representative or otherwise interact with us by email, at online and physical events or in the course of our business activities;
- may also collect personal information from third parties, such as background checking service providers, social networks, public databases (where permitted by law), corporate websites, your business associates (including your buyers / suppliers), Stenn representatives who may invite you to use our services and our partners where we carry out joint business activities; and
- may automatically collect personal information about how you access and use the Site and information about the device you use to access the Sites and our newsletters (such as the pages you visit).
Please note that if you create your account on the Site using your Facebook login details, you give permission to Facebook to share with us your name, profile picture and email address. If you create an account using your Google login details, you give Google permission to share with us your name, email address, language preference, and profile picture (if you have one).
We use the information we collect in relation to you to correspond with you, perform our agreements (including with you or the organisation you represent), comply with our regulatory responsibilities and policies such as anti-money laundering, carry out marketing activities and day-to-day business activities and operations.
We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
We will indicate to you where the provision of certain personal information is required in order for us to provide you certain services. If you choose not to provide such personal information, we may not be able to provide the services you have requested.
Analytics and research
We may use personal information that we collect about you for purposes that include testing our IT systems, research, data analysis, improving our Site and developing our invoice financing services and new products and features. Where appropriate, we will anonymise your information for these purposes.
Data retention
We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 in accordance with our legal obligations and legitimate business interests.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.
Recipients of personal information
We may share your personal information with the following (as required in accordance with the uses set out in Annex 1):
- Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing email, advertising, fraud prevention, background and anti-money laundering checks, web hosting, or providing analytic services.
- Business partners: we may share your personal information (such as contact details) with our business partners, such as trade credit providers, where this is necessary in the normal course of our business.
- Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
- Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that 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: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.
Marketing and advertising
From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
We will only send you marketing messages if we have your consent or, if consent is not required under applicable law, you have not opted out of receiving messages from us. You can withdraw your consent or opt out of receiving further communications at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.
Storing and transferring your personal information
Security. We implement appropriate technical and organisational measures, including encryption, to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password or national identification numbers.
International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where our affiliates and our third party service providers have operations. If you are located in the UK or European Economic Area ("EEA"), your personal information may be transferred outside of the UK and EEA respectively. These international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. 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.
Your rights in respect of your personal information
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
- Right of access. You have the right to obtain access to your personal information.
- Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information 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.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to object. You have a 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.
- Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent.
Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
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 information you have submitted to us by logging into your account on our website.
You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, information on how to contact the Information Commissioner is available at www.ico.org.uk. If you are located in the EU, further information about how to contact your local data protection authority is available at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Cookies and similar technologies
Our website uses cookies to distinguish you from other users of our website. Please refer to our Cookies Policy for more information as to the way in which we use cookies on our Site.
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 information 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 information is collected through cookies and similar tracking technologies. We and our third party partners use this information 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.
To learn about interest-based advertising and how you may be able to opt-out of some of this advertising and to limit some third party advertising cookies, you may wish to visit:
- Your Online Choices (http://www.youronlinechoices.com/)
- Network Advertising Initiative (http://www.networkadvertising.org/)
- Digital Advertising Alliance (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-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her 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.
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.
Changes to this policy
We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
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.
Contacting us
If you have any questions, comments and requests regarding this Privacy Policy, you can contact us:
By post:
FAO Legal Department
V101, 1-45 Durham Street
London
SE11 5JHBy email: welcome@stenn.com
This privacy policy was last modified on the 13 April 2021.
| Category of personal information | How we use it | Legal basis for processing |
|---|---|---|
| Contact details (name, business, email, phone number); employment information (job title, employer); account details (username, password and social media details (if applicable)) |
| Such processing is in our and your legitimate interests to ensure the organisation you represent is provided with our services in accordance with our contract with that organisation. Either consent (if required under applicable law) or our legitimate interests, namely marketing and advertising to our contacts and customers to grow our business. Such processing is necessary for our legitimate interests, namely to ensure we are able to resolve any issues you have in accessing the Site or using our services. Such processing is necessary for our legitimate interests, namely to ensure you are aware of any changes to our policies, terms and other such technical updates. |
| Identification information (name, passport, utility bills and other identification information), background information |
| Compliance with a legal obligation. If not required under law, then such processing is in our legitimate interests to ensure we are engaging with suitable businesses to protect our own business. |
| Contact details (name, email, phone number) |
| It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business. |
| Contact details (name, email, phone number); bank account details |
| Performance of a contract. |
Technical information (IP address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location); Usage data (clickstream to, through and from the Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, and website navigation and search terms used) |
| Consent. |