Privacy Policy

SUTTON PLACE STRATEGIES WEBSITE AND PORTAL PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE OR
SUBMITTING ANY PERSONAL DATA TO SUTTON PLACE STRATEGIES

Sutton Place Strategies, LLC (“SPS” or “we”) is the developer and owner of the Sutton Place Strategies website located at suttonplacestrategies.com (the “SPS Website”) and the web based portal and application which provides certain functionality and tools to analyze and review private equity deal information, which includes, without limitation, all associated computer software, functionality, features, media, printed materials, and “online” or electronic documentation (collectively, the “SPS Portal”). The SPS Portal is available through the website at   sclientportal.com. SPS provides to its clients and their users (individually, a “Client” and collectively, “Clients”) the right to use the SPS Portal pursuant to your agreement with SPS and the SPS Portal Terms of Use (“Terms”) entered into by and between SPS and Clients. Please review our Terms, which governs your use of the SPS Portal and any content you submit to the SPS Portal.

Your privacy is important to SPS. As part of your use of the SPS Website and SPS Portal, personal data is gathered about you (individually, a “User” and collectively, “User”). This Privacy Policy contains explanations regarding the types of information collected, how that information may be used or disclosed, and how to correct or change the information.

By using the SPS Website, SPS may collect your IP address. Should you wish to sign up to any newsletters or talks, or request a demo, you will also need to provide your email address. By using the SPS Portal you will be required to provide SPS certain personal data. This data includes: (a) first and last name, (b) email address, (c) mobile phone number, and (d) company name (collectively, “Personal Data”). You hereby agree to allow SPS and its affiliates to access, store, display, transmit, process, and use the Personal Data, and any information directly related to the SPS Portal. All such Personal Data will be processed in accordance with this Privacy Policy

SPS agrees to materially comply with all applicable privacy laws in connection with its collection, storage and use of Personal Data. SPS recognizes that privacy is an important issue. This Privacy Policy outlines the types of Personal Data we may collect when you use the SPS Website and SPS Portal, how we use and may disclose that information, as well as the steps we take to safeguard it. We require you to read this Privacy Policy in its entirety so that you can make an informed decision about sharing your Personal Data with us.

SPS reserves the right to change this policy at any time. Please check this page periodically for changes. Your continued use of and access to the SPS Website and SPS Portal following the posting of changes to these terms will mean you accept these changes. SPS may take reasonable measures to notify you if there is a material change in our privacy practices with respect to use of the Personal Data you have provided to SPS. If you have any questions about this Privacy Policy, SPS’s privacy practices, or feel that your privacy has been compromised, please contact SPS by email at info@suttonplacestrategies.com.

Opting-out:

Even after you have consented to SPS’s collection and use of your Personal Data and submitted Personal Data to SPS, you may opt-out of having your Personal Data collected or used by SPS by contacting us, however when you opt-out of having your Personal Data collected or used by SPS your ability to use the SPS Website and SPS Portal will be limited. Please note that in order to fulfill certain obligations, we may need to continue sending you notices or other important information concerning any services you request. You may contact SPS by emailing us at info@suttonplacestrategies.com or calling us at 212-376-6129.

COOKIES:

Like many websites, SPS uses “cookies” on the SPS Website and SPS Portal to improve its performance and enhance your user experience.

What are Cookies?

A cookie is a small text file which is placed on your device. Cookies help to analyze web traffic and allow web applications to respond to you as an individual. The web application can then tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Certain cookies may contain personal data – for example, if you click to “remember me” when logging in, a cookie may store your username and password. Most cookies won’t collect personal data that identifies you, and will instead collect more general information, such as how Users arrive at and use the SPS Website or SPS Portal.

What kinds of Cookies do we use?

The SPS Website and SPS Portal utilize both Session and Persistent Cookies. Session cookies are used ‘in-session’ each time you visit the SPS Website and SPS Portal and then expire when you leave the SPS Website or SPS Portal or shortly thereafter: they are not stored on your device permanently, do not contain any personal data and help by minimizing the need to transfer personal data across the internet. These cookies can be deleted but this will hamper the performance and your experience in using the SPS Website and SPS Portal. These cookies also take time stamps that record when you access the SPS Portal and when you leave the SPS Portal.

Persistent Cookies are used on the SPS Website from Google and YouTube and on the SPS Portal for log-in purposes only. These cookies are encrypted and persist even after your browser is closed. On the SPS Website, the Persistent Cookies persist for up to two years. On the SPS Portal, the Persistent Cookie persists so that you do not need to log-in again when you next visit and expire after seven days from the last log-in.

Can the Cookies be blocked?

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services on the SPS Website or SPS Portal may not work properly because we may not be able to recognize and associate you with your SPS account(s).

GENERAL PRIVACY PRINCIPLES

Personal Data You Provide to Us:

SPS requires Personal Data in connection with your use of the SPS Website and/or registration and use of the SPS Portal and we use the Personal Data that you submit so that we can verify you’re your eligibility, process your requests, connect you with our deal information services, contact you about services, process your communications, or comply with the law.

Limited Use, Disclosure and Retention:

Except as otherwise set forth in this Privacy Policy under the heading Limits of Confidentiality or as required by law, SPS does not use, disclose or retain your Personal Data for purposes other than those for which it was collected or as required by law. Your Personal Data is retained only as long as necessary for the fulfillment of those purposes or as required by law.

Accuracy:

Your Personal Data is kept as accurately and completely as is necessary for the purposes for which it is to be used. You have the right to update, modify, amend or correct errors in your Personal Data by updating it in the SPS Portal or contacting SPS by email at  nfo@suttonplacestrategies.com.

Safeguards:

SPS protects your Personal Data by using safeguards that SPS believes are appropriate to the sensitivity of the information. We maintain certain administrative, technical and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of your Personal Data. Each of our employees, subcontractors, or business partners who have access to your Personal Data is informed about our Privacy Policy and procedures for protecting Personal Data.

SPS undertakes substantial efforts to protect the confidentiality of the Personal Data and other information it has collected about individual Clients and Users, and except as otherwise set forth in this Privacy Policy including, without limitation, under the heading Limits of Confidentiality, will not intentionally disclose this information to anyone outside SPS.

Except as otherwise set forth in this Privacy Policy, we restrict access to your Personal Data to employees, affiliates, subcontractors, or business partners who need to know that information in order to perform their jobs or duties and provide services to you. We review our data collection, storage and processing practices and security measures, as well as physical security measures intended to guard against unauthorized access to systems where we store Personal Data, on a periodic basis.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your personal information transmitted to the SPS Website or SPS Portal. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the SPS Portal.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to the SPS Portal, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Breaches:

In the event that there is ever a breach of security regarding your Personal Data, we intend to comply with applicable state and federal law requirements regarding the notification and disclosure to you and to the appropriate authorities of the circumstances surrounding the breach.

Access:

Upon request by email to info@suttonplacestrategies.com you will be given access to your Personal Data within a reasonable timeframe. SPS will assist any User who informs us that they need assistance in preparing a request concerning Personal Data. You may also request to have your Personal Data amended as appropriate, or request that SPS delete or correct any of your Personal Data.

Limits of Confidentiality:

By using the SPS Website or the SPS Portal and sharing your Personal Data with us, you will have opted-in to our collection, disclosure and use of your Personal Data and any non-Personal Data under this Privacy Policy.

We may use your Personal Data for the purposes of sending you registration and authentication information for the SPS Portal, maintaining your account, processing your requests, providing you with deal information, metrics and other services, processing your communications, and communicating with you by email and phone about the SPS Portal, SPS, and other related services. We may also use Personal Data for auditing, research and analysis to operate and improve SPS’s technologies, systems, and services.

We do not sell any of your Personal Data (including your name, email, or phone number) to any companies or third parties, nor will we sell your Personal Data except in a sale or transfer of our business pursuant to subsection (iii) below. We also do not share any of your Personal Data with unaffiliated or non-agent third parties for the purpose of marketing or promoting our products or services to you.

Further, when you send email communications to SPS, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. We may share your Personal Data in any of the following circumstances:

(i) Affiliated or Third Party Businesses. We may provide your Personal Data to our subsidiaries, affiliated companies, or other trusted businesses or persons (“Affiliated or Third Party Businesses”) for the purpose of processing or storing Personal Data on our behalf. These Affiliated or Third Party Businesses include, without limitation, third parties we use to assist us in our mission of providing you with the SPS Portal such as data center hosting providers. The Personal Data that we process or that is processed for us may be transmitted to and stored on the servers of Affiliated or Third Party Businesses. When we do disclose your information to others, it is subject to agreements that require those parties to process such information in compliance with this Privacy Policy, and in an appropriate confidential and secure manner.

(ii) Security and Legal Obligations. Due to the existing legal, regulatory and security environment, SPS may disclose aggregate level and/or Personal Data about its Clients and Users to protect the rights, property or safety of SPS, or the public, to prevent fraud or imminent harm, and in connection with providing for the security of our computer systems, computer network, telecommunications network, products and services. SPS also may use and disclose your Personal Data: (1) to the extent required to respond to a legal or ethical obligation, (2) to the extent necessary to meet national security, public interest or law enforcement obligations, and (3) to the extent expressly permitted by an applicable law, rule or regulation. Additionally, your Personal Data may be disclosed as required by applicable law, to comply with a court order, subpoena, warrant or other legal process, or where the personal data is publicly available (unless otherwise restricted by applicable law).

(iii) Sale or Transfer of Business. We may sell or otherwise transfer your Personal Data to a successor of SPS, or any subsidiary or division of SPS in connection with an asset sale, acquisition, merger, consolidation, divestiture, purchase of part or all of the assets of the business, or other corporate transaction, or by way of assignment (whether by operation of law or otherwise) in connection with any such or similar transaction or in connection with the administration of a bankruptcy estate. In the case of such event, SPS’s systems, technology, intellectual property, and data, including Personal Data, will become the property of the successor and will be subject to the successor’s Privacy Policy should they have one.

Accountability:

SPS has appointed an officer who is accountable for SPS’s compliance with this Privacy Policy. All questions regarding this policy can be sent to info@suttonplacestrategies.com.

Minors Under the Age of 18:

SPS is committed to protecting the privacy of minors. Our policy is that we do not knowingly collect, use or disclose Personal Data about Clients or other users that we know are under 18 years of age. This SPS Website ot Portal is not directed in any respect to anyone under the age of 18. If we learn that we have collected or received personal information from an individual under the age of 18 without verification of parental consent, we will delete that information. If you believe we might have information from or about an individual under the age of 18, please contact us at: info@suttonplacestrategies.com.

CONSENT:

YOUR KNOWLEDGE AND CONSENT ARE REQUIRED FOR THE COLLECTION, USE, OR DISCLOSURE OF YOUR PERSONAL DATA IN THE SPS PORTAL. BY SUBMITTING YOUR PERSONAL DATA TO SPS, YOU HEREBY CONSENT TO SPS’S COLLECTION, USE AND DISCLOSURE OF SUCH INFORMATION. IF YOU DO NOT CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, YOU SHALL NOT SUBMIT SUCH INFORMATION TO SPS.

Date of last update: January 19, 2021