THE STERLING MANHATTAN PRIVACY AND DATA POLICY
STERLING MANHATTAN and its holding company TIMESTWO INVESTMENTS (herby known as SM and X2) are committed to maintaining the trust and confidence of visitors to its website and anyone interacting with us online and via email/email forms. In particular, we are committed to safeguarding the privacy of any data collected from those visiting our website.
When someone visits the SM website, data is collected that helps improve the website and our associated services. By using the website, you agree to the collection and use of information in accordance with this Privacy Policy. You also consent to our website’s use of cookies in accordance with the terms of this Policy.
This Privacy Policy sets out detailed information on when your personal information is collected, how it is used and how it is kept secure.
Definitions
Personal Data
Personal Data means data about a living individual who can be identified from that data.
User
The User is the individual using the Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Data Subject
The Data Subject is any living individual who is the subject of Personal Data.
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small pieces of data stored on a User’s device.
Data Controller
Data Controller means a person who (either alone or jointly) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Information Collection And Use
SM and X2 collect different types of information. This is for various purposes to provide a service to you and improve the SM website.
Types of Data Collected
Personal Data
While using the SM website, you may be asked to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This may include:
- Email address;
- First name and last name;
- Cookies and Usage Data.
Your Personal Data may be used to contact you via email or with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email that is sent or by contacting us.
Usage Data
Information about how the website is accessed and used may also be collected. This may include information about your computer and about your visits to and use of this website (including your IP address, geographical location browser type and version, operating system, referral source, length of visit, page views and website navigation paths) and other diagnostic data.
Tracking & Cookies Data
Cookies and similar tracking technologies are used to track the activity on the website and hold certain information.
The SM uses cookies to distinguish you from other users of the Service and helps to provide a good browsing experience whilst also allowing us to improve this website.
The SM uses cookies and similar tracking technologies to track the activity on the Service and hold certain information.
Examples of Cookies in use:
- Session Cookies. Session Cookies to operate the Service;
- Preference Cookies. Preference Cookies to remember your preferences and various settings;
- Security Cookies. Security Cookies for security purposes.
What are your choices regarding cookies?
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
If you would like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
Use of Data
We use the collected data for various purposes:
- To provide and maintain the website;
- To notify you about changes to the website and associated services;
- To allow you to participate in interactive features of the website when you choose to do so;
- To provide customer support;
- To gather analysis or valuable information so that the website can be improved;
- To monitor the usage of the website;
- To detect, prevent and address technical issues.
Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
SM and X2 will also retain Usage Data for internal purposes. Usage Data is generally retained for a shorter period of time except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United Kingdom and process it here.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
The SM will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Security Of Data
The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Disclosure Of Data
Legal Requirements
The SM and X2 may disclose your Personal Data in the good faith that such action is necessary to:
- To comply with a legal obligation;
- To protect and defend the rights or property of the SM and X2;
- To prevent or investigate possible wrongdoing in connection with the Service;
- To protect the personal safety of users of the Service or the public;
- To protect against legal liability.
Service Providers
We may employ third party companies and individuals to facilitate our Service to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
When you visit our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as numbers of visitors to various parts of the site. This information is only processed in a way which not does not identify anyone. We do not make, and do not allow, Google to make any attempt to find out the identities of those visiting our website. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Social Media Sharing
A Facebook widget is embedded to allow you to “like/share/recommend” our webpages. This widget may collect your IP address, your web browser User Agent, store and retrieve cookies on your browser, embed additional tracking, and monitor your interaction with the widget, including correlating your Facebook account with whatever action you take within the widget (such as “liking/sharing/recommending” our webpage), if you are logged in to Facebook. For more information about how this data may be used, please see Facebook’s data privacy policy: https://www.facebook.com/about/privacy/update
A Twitter Tweet widget is embedded in our website. As a result, our website makes requests to Twitter’s servers for you to be able to tweet our webpages using your Twitter account. These requests make your IP address visible to Twitter, who may use it in accordance with their data privacy policy: https://twitter.com/en/privacy#update
A LinkedIn Share widget is embedded in our website to allow you to share our webpages on LinkedIn. These requests may track your IP address in accordance with their data privacy policy: https://www.linkedin.com/legal/privacy-policy
Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes To This Privacy Policy
This Privacy Policy may be updated from time to time. The New Privacy Policy will be posted on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Access to your Personal Information
Under GDPR, you have the right to view, amend or delete the personal information that we hold on you. Please email your request to
Please note that we may ask you to verify your identity before responding.
Contact Us
If you have any questions about this Privacy Policy, please contact us at: info@sterlingmanhattan.co.uk