General Data Protection Regulation (GDPR) Privacy Policy
This GDPR Privacy Policy governs the manner in which Raistone Capital LLC, Raistone Purchasing LLC and our affiliates (“Raistone”, “we”, “our” and “us”) collect, use, maintain, retain, share and disclose personal information about you, an individual who is a citizen of the European Union (in other words “you” are a natural person and a citizen of the EU), and supplements our Privacy Policy. “you” does not refer to a corporation or limited liability company.
We have put in place appropriate and suitable safeguards to protect your personal information, and that the transfer of your personal information is in compliance with the requirements and the obligations provided by applicable data protection laws, such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the EU General Data Protection Regulation 2016/679.
Data Controller – The data controller for this website is Raistone. We are located at 360 Madison Avenue, 22nd Fl. New York, New York 10017, USA.
What we collect – We collect basic personal data about you which does not include any special types of sensitive personal information. This does, however, include first name, last name, company name, job title, geographic location, phone number, email, and other business contact details. Click here for a more detailed list of what we collect.
Why we collect – We collect your Personal Data in: providing, maintaining, diagnosing, improving and administering the Site and Services; marketing; analyzing and profiling you and other users; systems and data security; assessing and supporting our Contractors and Service Providers. Click here for a more detailed list of why we collect your Personal Data.
Where we process – We are a U.S. company, but we may work with and process data about individuals across the world. To operate our business, we may store or process your personal information outside of your home country, including in the United States or Canada, as permitted by an Adequacy Decision adopted by the European Commission pursuant to Article 45 GDPR.
Where we get it – Your Personal Data originated directly from you, your Company or from third-party commercial and/or publicly-accessible sources. Click here for a more detailed list of what where we collect your Personal Data.
How long we keep it – Your Personal Data used for transactional and marketing purposes will be kept with us until you notify us that you no longer wish to receive this Service [or as otherwise covered under the policy].
Your data will be shared with individuals within Raistone where it is necessary for them to undertake their duties with regards to the Site or the Services or conducting any business or having any communications with your Company.
It may be necessary for us to share your personal data with a third party or third party service providers (including, but not limited to, those who might purchase invoices from your Company or to the those to whom the invoices are issued or are otherwise responsible for payment) within, or outside of, the European Union (EU). Data sharing may arise due to a legal obligation, as part of the performance of a contract or in situations where there is another legitimate interest (including a legitimate interest of a third party) to do so.
The list below identifies which activities are carried out by third parties on our behalf:
· IT services
· legal and accounting advisors
· security
· advertising, referral or data brokers
Data may be shared with third parties in at least the following circumstances:
· in relation to the maintenance support and/or hosting of data
· to adhere with a legal obligation
· in the process of obtaining advice and help in order to adhere with legal obligations.
If data is shared, we expect third parties to adhere and comply with the GDPR and protect any personal data of yours that they process. Our contracts with third parties restrict the third parties from processing personal data for their own reasons, although in some cases the third party can process your consumer data in order to consider and determine whether they should enter into a contract with Raistone, maintain a contract with Raistone or otherwise administer or enforce a contract with Raistone. Where they process your data it is for a specific purpose according to our instructions.
See also the information above as to Why We Collect
What are your data protection rights under the GDPR?
We list here your data protection rights under the GDPR. You may have other rights under the GDPR.
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
The right to erasure — You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the personal data that we have collected on you to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any
of these rights, please contact us at our email: Privacy@raistone.com
Call us at: 888-626-6593
Or write to us: 360 Madison Avenue, 22nd Fl. New York, New York 10017, USA, Attn: General Counsel
The above rights are subject to applicable limitations and restrictions. In certain cases, your request may be denied based on a legitimate exception such as where we are prevented from disclosing such information based on legal requirements, fraud prevention, or security concerns, or when we need to maintain the information. For more information, to make a request, or if you wish to raise a complaint on how we have handled your Personal Data, you can contact our Data Protection Representative at Privacy@raistone.com.
Processing Information About You
In our good faith judgement, at least one of the following lawful bases will apply when we process your personal data:
· consent: You have given clear consent for us to process your personal data for a specific purpose.
· contract: The processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
· legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
· vital interests: the processing is necessary to protect someone’s life.
· public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
· legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party (such as, but not limited to, your Company) unless there is a good reason to protect your personal data which overrides those legitimate interests.
Cookies
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General
Raistone may revise this GDPR Policy at any time by updating this page on the Site and in such event your continued use of the Site or Services shall constitute your acceptance of such updated GDPR Policy. Accordingly, you should visit this page from time to time to review the then-current GDPR Policy because it is binding on you. Certain provisions of this GDPR Policy may be superseded by expressly designated legal notices or terms located on particular pages at the Site. All agreements, notices, disclosures and other communications that we provide to you electronically or posted on the Site shall satisfy any legal requirement that such communications be in writing if such requirements are applicable. For more information regarding this GDPR Policy, or if you have any questions or concerns, you may contact us in the following ways:
You may contact Raistone at c/o Raistone Capital LLC at the following address:
360 Madison Avenue, 22nd Floor, New York, NY 10017, by calling our toll-free phone number: 888-626-6593, or by emailing us: Privacy@raistone.com
Effective as of [September 14 , 2023]