Privacy Policy

Suite LLC Privacy Notice and Cookie Policy

Introduction

Suite, LLC (Suite, we, our, us) respects your privacy and is committed to protecting your personal data. This privacy notice explains how we use and protect the personal data you provide to us. It also explains your privacy rights and protections.

We have tried to keep this privacy notice simple without compromising on the information provided to you. We have therefore broken it down into the following sections:

1. Important information and Suite LLC’s details
2. The personal data we collect
3. How your personal data is collected
4. How we use your personal data
5. Disclosure of your personal data
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights

1. Important Information and Suite, LLC’s details

Purpose of this Privacy Notice
This privacy notice gives you information about how we collect and process personal data you provide to us, including any data you provide via our website (https://www.suitellc.com) when you register with us, use our software, receive services or when you provide us with your contact details through day to day business contact.

Our contact details
We are the data controller responsible for your personal data given to Suite. Our details are:

• Name: Suite, LLC (“Suite”)
• Address: 99 Wall Street, Suite 880 New York, NY 10005
• Email address: support@suitellc.com
• Telephone number: +1- 212-485-3200

If you have any questions about this privacy notice, including any requests to exercise your legal rights (see below), please contact the data privacy manager using the details set out above.
You have the right to make a complaint at any time to the Information Commissioners Office (ICO) (www.ico.org.uk ) which is the supervisory authority for UK data protection issues. However, we ask that you contact us first and give us the opportunity to address any concerns before you consider contacting the ICO.

It is important that the personal data we hold about you is accurate and current, so please let us know if your personal data changes at any time.

Third party links
Suite’s site may provide links to third-party Web sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party websites and are not responsible for their privacy statements or their data management, nor are we responsible for any personal information you may provide while on such sites. We encourage you to read the privacy notice of any website you visit.

2. The Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).

We may collect, use, store, and transfer the following kinds of data:

• Identity Data: Includes first name, last name, username, password or similar identifier.
• Contact Data: includes company address, email address, and telephone numbers.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology information on the devices you use to access this website or our software.
• Usage Data: includes information about how you use our website and services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

The above categories are used as defined terms elsewhere in this privacy notice, in particular section 4.

We do not collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, genetics, or biometric data). Our business offering is not intended for children and we do not knowingly collect data relating to children.

3. How your personal data is collected

We use different methods to collect your personal data including through:
Directly from you: you may give us your Identity and Contact Data either face to face, or by filling in forms or corresponding with us by phone, email, or otherwise. This includes personal data your provide when you:

• Use our services
• Create an account on our site
• Subscribe to our service or publications
• Request marketing materials to be sent to you
• Meet us at business or networking events
• Give us some feedback

Automated technologies or interactions
As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Our cookie policy is set out below:

Use of cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to be more responsive to you. The web application can tailor its operations to your needs, likes and dislikes, by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in now way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookie if you prefer This may prevent you from taking full advantage of the website.

Third parties or publicly available sources
We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:
  • Analytics providers such as Google based outside the EU
  • Advertising networks
• Identity and Contact Data from list suppliers based inside or outside the EU
• Identity and Contact Data from publicly available sources such as LinkedIn based outside the EU

4. How your personal data is used

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform our business contractual obligations to your business.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override these interests.
• Where we need to comply with a legal or regulatory obligation.

Legitimate interest(s) means the interest of conducting and managing our business to enable us to give you good services/products and a good and secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where are interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Please contact us if you would like any further guidance concerning how we assess legitimate interests against any potential impact on you.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by unsubscribing or contacting us.

Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and the legal bases we rely on in doing so. We have also identified what our legitimate interests are where appropriate.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms regarding our marketing activities:

Promotional or educational information from us
We may use your Identity, Contact, Technical, and Usage Data to decide what we think you may want or need, or what may be of interest to you to use our site and services more effectively.

You may receive technical and marketing communications from us if you have requested information from us or licensed services from us and in each case, you have not opted out of receiving that marketing.

Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at support@suitellc.com.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal da for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Professional advisors including lawyers, accountants and auditors based in and out of the EU who provide legal and accounting services.
• Revenue & Customs, regulators and other authorities based in and out of the EU who may require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with out instructions.

6. International transfers

Your personal data is held in US secure environments. Our employees, agents and associates may view your data over internet devices in and outside the European Economic Area from countries such as Japan as well as the US. We ensure that your data is subject to the same security processes as the US business.

Whenever we transfer your personal data, we ensure that the data is subject to the same security processes as the US business.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?
We will only retain your personal data as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Personal data retention periods are summarized in the table in section 4.

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 unauthorized 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, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have Data Subject Rights under data protection laws in relation to your personal data. You can find further information from the Information Commissioners website at www.ico.org.uk.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy, (b) where our use of the data is unlawful but you do not want us to erase it, (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at support@suitellc.com.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need form you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your acceptance of these terms
By using the Suite, LLC website, you consent to the collection and use of your information by Suite, LLC as set out in this privacy and cookie policy. If we change our privacy policy in any way, these changes will be posted on this page.

Please email any questions, concerns, or comments you have about this policy to:

support@suitellc.com
Telephone: +1-212-485-3200
Suite, LLC
99 Wall Street, Suite 880
New York, NY 10005