Commitment to Privacy & Confidentiality
For all Visitors to Our Website and Users of the Stratosphere Solutions Limited Platform
Stratosphere Solutions Limited operates a cloud-based business network and execution platform for global trade and supply chain management, as well as our marketing website(s) and various services, applications, products and content (the “Stratosphere Solutions Limited Platform”). We post our Privacy and Confidentiality Policy to inform you and/or your organization (collectively “you” or “your”), as a visitor to our marketing website, a user of the Stratosphere Solutions Limited Platform, what kinds of information we may gather about you, how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of information, and your ability to correct that information. By accessing the Stratosphere Solutions Limited Platform, you are consenting (i) to this Privacy and Confidentiality Policy and (ii) to having your personal data transferred to and/or processed in the United States in accordance with the terms of this Privacy and Confidentiality Policy. Stratosphere Solutions Limited collects all data collected through our website and is responsible for implementing and ensuring compliance with this Privacy and Confidentiality Policy. For information regarding Stratosphere Solutions Limited ’ Data Security Policy, please visit our website.
Please note that this Privacy and Confidentiality Policy applies only to the Stratosphere Solutions Limited Platform, and not to other companies’ or organizations’ websites to which we link or to companies to which we refer a Stratosphere Solutions Limited Platform member (a “Member”) (as an example to companies who may provide services for our Members). These sites may collect information about you. Stratosphere Solutions Limited does not control sites that are operated by others and is not responsible for the information practices of these sites and this Privacy and Confidentiality Policy does not address the information practices of those websites or operators thereof.
Visitors to Our Marketing Websites
When you visit our marketing website and/or any affiliated Stratosphere Solutions Limited owned website (collectively, the “Website”), we do not collect personally identifiable information about you except when you specifically and knowingly provide it. For instance, if you request information from us, you will be asked to provide basic information about you and your organization, including your name, company, title, country, e-mail address, your company’s industry and other information that may assist us in providing services to your organization (the “Basic Information”). Stratosphere Solutions Limited does not intentionally or knowingly collect sensitive personal information such religious beliefs, political opinions, health, sexual orientation, race or union membership. The Stratosphere Solutions Limited Platform is not intended for and does not knowingly collect information from children under the age of 13.
We do not sell, trade, or rent to any third party any of the Basic Information that you provide to us prior to your organization becoming a Member of the Stratosphere Solutions Limited Platform. We may provide Basic Information to third parties who provide services to us, and who agree to abide by the terms of this Privacy and Confidentiality Policy. We will use the Basic Information you provide to respond to your requests for additional information by email.
Required cookies enable you to navigate Stratosphere Solutions Limited Platform and use its features, such as accessing secure areas of the websites and using Stratosphere Solutions Limited services. Because required cookies are essential to operate the Stratosphere Solutions Limited Platform, there is no option to opt out of these cookies and continued use of the site implies consent.
Performance cookies collect information about how visitors use the Stratosphere Solutions Limited Platform, including which pages visitors go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies a visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve functionality and performance of our site.
Functionality cookies remember information you have entered or choices you made (such as your username, language, or your region) and provide enhanced, personal features. Opting out may impact the functionality of the Stratosphere Solutions Limited Platform.
Targeting or Advertising cookies
Third party advertising and retargeting pixels and cookies are used to manage and track the effectiveness of our marketing efforts. From time-to-time, third parties track and analyze usage and volume information from individuals who are referred to the site from ads. Third party advertising networks may collect IP addresses and other information from web beacons, emails, and on third-party websites, in order to provide advertisements about products and services tailored to your interests. You may see these advertisements on other sites.
Our system logs some basic and generic information about your computer, including its:
We use this information about your computer to perform routine website maintenance, to generate aggregate website traffic reports, and enhance the performance of our website on different browsers and devices.
We are committed to providing reasonable and practical access to you to identify and to correct any inaccuracies in the information you may provide.
Stratosphere Solutions Limited Member Information
If your organization chooses to apply for membership to the Stratosphere Solutions Limited Platform, you may be asked to provide Basic Information for individuals who will act as contacts on Stratosphere Solutions Limited and detailed financial and business information about your organization. This information may be shared with financial service providers and payment providers to enable your organization to qualify for credit risk and payment services. During this registration process, we will allow you to choose whether or not you would like us to contact your organization’s trading partners for membership and other services related to transactions.
Once your organization becomes a Member, your Basic Information and your organization’s financial information, other confidential business data, and transaction details may be shared with other Members, Stratosphere Solutions Limited service providers, and Stratosphere Solutions Limited corporate alliances as necessary in order to conduct your transaction(s). Stratosphere Solutions Limited service providers and corporate alliances include, but are not limited to payment providers, payment protection providers, country managers, freight forwarders, inspection agents, logistics providers, financing providers, sales support, marketing agents, and, subject to appropriate restrictions, to third parties who provide services to us regarding our business. In certain circumstances, we may modify the format of information you provide to us to make the format compatible with the Stratosphere Solutions Limited Platform. We will not disclose your Basic Information and your organization’s financial information, confidential business data or transaction details without your consent, except as permitted by this Privacy and Confidentiality Policy or a Stratosphere Solutions Limited Membership Agreement, our Master Subscription Agreement or any other agreement you or your organization have accepted with Stratosphere Solutions Limited to govern your access to the Stratosphere Solutions Limited Platform (the “Stratosphere Solutions Limited Agreement”). Note that settlement services are provided through a Stratosphere Solutions Limited , Inc. subsidiary, Platform Settlement Services LLC (“PSS”) and Members are required to enter into a separate Platform Settlement Services User Agreement with PSS, which shall be the entire agreement between such parties.
In addition, we aggregate your transaction data with that of other Members for benchmarking, statistical analysis and other similar purposes (the “Stratosphere Solutions Limited Data”). Stratosphere Solutions Limited reserves all rights in the Stratosphere Solutions Limited Data, including but not limited to the right to commercialize Stratosphere Solutions Limited Data as the sole and exclusive property of Stratosphere Solutions Limited . Stratosphere Solutions Limited Platform pricing is based in part on Stratosphere Solutions Limited ’ reservation of all rights in the Stratosphere Solutions Limited Data, including the commercialization of Stratosphere Solutions Limited Data.
Passwords and identity or security devices are private entry keys into the respective Stratosphere Solutions Limited account. A user should never share his or her password or identity or security devices with anyone. If a user needs to walk away from his or her personal computing device (PC) for any reason, the user should log off from the Stratosphere Solutions Limited session. Users should select passwords that are difficult to guess and change them frequently. Passwords should not be stored on the PC or on written notes near the PC. Identity or security devices should be stored in a secure place. Stratosphere Solutions Limited is not responsible if the foregoing practices are not complied with.
When a user logs onto our transaction sites, the Stratosphere Solutions Limited system uses session cookies, small text files placed temporarily on your system, to maintain user session records. These cookies are destroyed as soon as the user logs out and closes the browser and cannot be used to track other information about the user or his or her computer. They are required; a user cannot use the Stratosphere Solutions Limited transaction system unless the user accepts these session cookies.
We will use the information you provide to contact you, if necessary, to service your organization’s account or for other administrative purposes. We may also access and use your organization’s information to resolve disputes, to troubleshoot problems, to enforce our Stratosphere Solutions Limited Agreement, or for marketing purposes. In addition, the Stratosphere Solutions Limited transaction system uses your transaction details to automate and to streamline your trade transaction by checking for electronic data compliance, providing reporting features, and transferring data from previous forms to those of the current transaction.
When this Privacy and Confidentiality Policy offers Members the opportunity to “opt in” or “opt out”, you may do so by contacting Stratosphere Solutions Limited Member Services on our website.
We are committed to providing reasonable and practical access to you to identify and to correct any inaccuracies in the information you may provide. Members can use the system’s administrative function to maintain up to date account information.
Disclosure of Information and Stratosphere Solutions Limited Data
We may disclose information about you and your organization to such third parties that you authorize.
We may provide Stratosphere Solutions Limited Data to third parties, including Members, provided that in no event will Stratosphere Solutions Limited use non-aggregated data that is captured by the Stratosphere Solutions Limited Platform, which represents a specific relationship and/or transaction between Members of the Stratosphere Solutions Limited Platform. Such data is not Stratosphere Solutions Limited Data and Stratosphere Solutions Limited will never use Stratosphere Solutions Limited Data to expose the nature of Member relationships or identify specific transaction details between Members.
Stratosphere Solutions Limited shall disclose information provided by you, about you and/or your organization, to the extent required by law through subpoena, search warrant or other legal process or requirement or as necessary to protect the rights, property, or safety of Stratosphere Solutions Limited , our Members, or others.
Stratosphere Solutions Limited reserves the right to change this Privacy and Confidentiality Policy, or any other Stratosphere Solutions Limited policy or practice, at any time. You are responsible for checking this page periodically for changes. When we intend to make material changes to this Privacy and Confidentiality Policy, we will post those changes on this page and such changes are effective immediately upon posting. Your use of the Stratosphere Solutions Limited service following any posted change(s) to the Privacy and Confidentiality Policy will be deemed an acceptance of such change(s). This Privacy and Confidentiality Policy is incorporated into, and part of, the Stratosphere Solutions Limited Agreement between you and Stratosphere Solutions Limited , if any.
We will endeavor to respond to your request to access, update or delete Member information as soon as practicable after you provide such updates to Stratosphere Solutions Limited.
Stratosphere Solutions Limited takes reasonable precautions to protect your Basic Information and your organization’s information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Please visit our website for more information regarding Stratosphere Solutions Limited ’ Data Security Policy. Due to the inherent nature of the Internet as an open global communications vehicle, Stratosphere Solutions Limited cannot guarantee that your information will be absolutely safe from intrusion by others, such as hackers. Any unauthorized access to or use of the Stratosphere Solutions Limited sites or information collected and maintained by the Stratosphere Solutions Limited sites should be immediately brought to the attention of Stratosphere Solutions Limited. Stratosphere Solutions Limited will investigate, and if necessary take action to prevent or halt, any violation of this Privacy and Confidentiality Policy of which it becomes aware. If you contact Stratosphere Solutions Limited by e-mail, you should be aware that e-mail transmission might not be secure. A third party could view information you send by e-mail in transit. Stratosphere Solutions Limited will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during transmission.
In the event that Stratosphere Solutions Limited , or substantially all of its assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such databases containing Member information may be one of the transferred assets. In using the Stratosphere Solutions Limited services, you consent to such transfer of your information.
US-EU Privacy Shield. Stratosphere Solutions Limited , which includes its respective successors, subsidiaries, divisions and groups, participates in and has certified its compliance with the EU-US Privacy Shield Framework. Stratosphere Solutions Limited is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the US Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list. Stratosphere Solutions Limited is responsible for the processing of personal data it receives, and under Privacy Shield, we may subsequently transfer that data to a third party acting as an agent on our behalf. Infor complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Infor is subject to the regulatory enforcement powers of the US Federal Trade Commission. In certain situations, Stratosphere Solutions Limited may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
US-Swiss Safe Harbor Stratosphere Solutions Limited , which includes its respective successors, subsidiaries, divisions and groups, participates in and has certified its compliance with the the US–Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Stratosphere Solutions Limited has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Infor’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
GENERAL DATA PROTECTION REGULATION
The General Data Protection Regulation (GDPR) is a comprehensive update to existing European Union laws that goes into effect on May 25, 2018. The GDPR was designed to harmonize data privacy laws across Europe, to protect and empower all EU resident’s data privacy and to reshape the way organizations across the region approach data privacy. The General Data Protection Regulation (GDPR) ( https://www.eugdpr.org/) the Data Protection Directive and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy. It will become effective on May 25, 2018 The GDPR applies not only to organizations who process data in the EU, but also any organization that offers goods or services to, or monitors the behavior of people inside the EU. GDPR applies even if the processing takes place outside of the EU The GDPR applies to information that directly or indirectly could identify an individual. This includes information, such as names, addresses, phone numbers, date of birth, as well as IP addresses, cookie identifiers, device information, advertising identifiers, financial information, geo-location information, social media information, consumer preferences, etc.
HOW DO WE COLLECT YOUR PERSONAL DATA
- We may collect your personal data when you directly provide it to us (by emails, by making an account etc).
We do not collect any sensitive data about you. Sensitive data according to GDPR is the personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation
We do not carry out any automated decision-making or any type of automated profiling.
We do not collect any information about criminal convictions and offences
- The security of your personal information is important for us and we protect it in several ways:
- your account password is encrypted;
- your personal information is encrypted when passed to us;
- your personal information is stored on a secured server;
- the information you enter on your registration or payment form is SSL encrypted;
The GDPR provides the following rights for individuals:
- The right to access: You can ask us for information regarding any data of yours that we keep at any time. This information concerns, among other things, the data categories we process, for what purposes we process it, the origin of the data if we did not acquire it directly from you and, if applicable, the recipients to whom we have sent your data. You can get a copy of your data from us for free. If you are interested in other copies, we reserve the right to charge for the additional copies.
- The right to rectification: You can request that we correct your data. We will initiate appropriate measures to keep the data of yours that we continuously process correct, complete, and up to date, based the latest information available to us.
- The right to erasure: You can request that we delete your data in case of:
The data is no longer required for the purposes it was acquired for or otherwise processed;
You revoke your consent, which is the basis of the data processing, and there is no other legal basis for the processing;
You object to the processing of your data and there are no legitimate reasons for the processing or you object to data processing for the purposes of direct advertising;
The data has been processed illegally;
Stratosphere Solutions Limited
Woodberry House, 2
Email: [email protected]