Your privacy is important to Sterling Investment Management, Inc. Please read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
1. Who we are
Our website address is: https://www.jacquettetimmons.com.
Sterling Investment Management, Inc. (“Sterling”), which owns and operates this website (jacquettetimmons.com), collects, uses and is responsible for certain personal information about you.
2. Children’s Online Privacy Protection Act
This website and any products and services offered herein are not intended for persons under the age of 13. “Sterling” does not knowingly collect information from anyone under 13 years of age. “Sterling” prohibits children under the age of 13 from using all interactive portions of this website, including leaving any comments, filling out forms, or otherwise submitting information. “Sterling” will not knowingly collect personally identifiable information from children under 13. If “Sterling” learns it has any information or content from anyone under the age of 13, it will delete that information.
3. The Personal Information We Collect and Use
a. Information Collected by Us
“Sterling” may collect, use, and is responsible for certain personal information that you provide when you voluntarily sign up for the Financial Wheel exercise and eCourse, e-mail list or other free gifts, register for a virtual or live event, leave comments, purchase a financial coaching service or product, fill out any type of form, access private membership pages, or otherwise contact “Sterling” via an online form or e-mail. The information collected may include your name, e-mail, address, telephone number, and/or billing information. You are not required to provide any personally identifiable information to merely access or visit this website.
If you are located in the European Economic Area (EEA), we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.
b. Information Collected from Other Sources
We also obtain your name, e-mail, telephone number, and limited financial data from other sources, such as ConvertKit, our e-mail marketing service provider; Acuity Scheduling, our third party appointment scheduling software; and Stripe and/or PayPal, our payment processor, via SamCart.
c. How we use your personal information
“Sterling” collects such information in order to send e-mails, fulfill orders, deliver services and products, complete customer transactions, oversee contests and promotions and improve website performance and customer service.
d. Who We Share Your Personal Information With
“Sterling” respects your privacy and will never sell, trade or transfer your personally identifiable information to third parties (beyond what is necessary for fulfilling a customer transaction or for the basic functionality of an online service) without your consent.
We do, however, share all or some of your personal data (e.g., your name, e-mail, phone number, and delivery address details) with our third-party suppliers and credit card processors, noted above in 3.b, in addition to the following: Copper CRM, our client relationship management software. For a list of where such third parties can be found, click here]. This data sharing enables us to provide you with the free and paid services you’ve voluntarily requested. It also enables us to manage how we create and deliver our free and paid services to you. Those aforementioned third-party recipients are based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see Transfer of your information out of the EEA.
“Sterling” may release personal information to enforce its Website Terms and Conditions of Use, other Terms and Conditions, manage its business, protect users or the general public, or to otherwise comply with legal obligations.
If you give “Sterling” your permission, it may also use personal identification information for internal or external marketing and promotional purposes.
On occasion, “Sterling” may collect personal identification information from you in connection with optional contests, special offers or promotions. “Sterling” will share such information with necessary third parties for the purpose of carrying out the contest, special offer or promotion. We will ask for your consent to such disclosure and use of such information, prior to your participation in the contest, special offer or promotion.
We will not share your personal information with any other third party.
e. Whether Information Has to Be Provided by You and Why
The provision of your name, e-mail, telephone number, mailing address, and financial data related to your payment method, such as credit card or bank transfer details, in relation to your purchase of a product or service, etc. is required from you to enable us to provide you with the free or paid product or service you voluntarily requested. Please note: We do not require you to provide any personal data in order to view the information on our website. We will inform you when we collect it whether you are required to provide the information to us.
f. How Long Your Personal Information Will Be Kept
We retain personal data as long as it is needed to conduct our legitimate business purposes and to comply with our legal obligations (e.g., UK tax law requires 6 years), or until you ask us to delete your data. Data that we gather for a specific and particular purpose, such as assisting law enforcement or analyzing trends, will not be kept for longer than is necessary for that particular purpose. Data that is no longer needed by us for any of the purposes listed above will be permanently deleted. Again, you may request that we delete your data at any time.
If you wish to have any third parties, including those to whom we’ve transmitted your data, delete that data, you will need to contact those third parties directly.
g. Reasons We Can Collect and Use Your Personal Information
“Sterling” collects and uses your personal information to further the following legitimate interests: to send e-mails, fulfill orders and purchase requests, deliver services and products, complete customer transactions, oversee contests and promotions and improve website performance and customer service.
4. Use and Transfer of Your Information Out of the EEA
This website is operated in the United States and third parties with whom we might share your personal information as explained above are also located in the United States. If you are located in the EEA or elsewhere outside of the United States, please be aware that any information you provide will be transferred to the United States. By using this website, participating in any of its services and/or providing your information, you consent to this transfer.
These countries do not have the same data protection laws as the United Kingdom and EEA. While the European Commission has not given a formal decision that the United States provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to the appropriate or suitable relevant safeguards e.g., European Commission approved contract – more examples here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/international-transfers/ as permitted under Chapter 5, “Transfers of personal data to third countries or international organisations,” Article 44-50 – click here for specific Article: https://gdpr-info.eu/chapter-5/, full text here: https://gdpr-info.eu – of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the such safeguards: https://gdpr-info.eu/art-40-gdpr/.
If you would like further information, (see “How to contact us” below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organization (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
5. Your Rights
If you want to unsubscribe from receiving e-mails from “Sterling,” you may do so at any time. Each e-mail from “Sterling” includes instructions for unsubscribing from these e-mail communications.
If you are covered by the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
- Fair processing of information and transparency over how we use your use personal information
- Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- Require us to correct any mistakes in your information which we hold
- Require the erasure of personal information concerning you in certain situations
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal information concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal information
- Otherwise restrict our processing of your personal information in certain circumstances
You may also have the right to claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, available at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .
If you would like to exercise any of those rights, please:
- Email, call, or write to us
- Provide us enough information to identify you (e.g., full name and the e-mail used to request your free or paid product or service)
- Provide us proof of your identity and address (i.e., a copy of your driver’s license or passport and a recent utility or credit card bill)
- Provide us with the information to which your request relates
6. Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable authorities of a suspected data security breach where we are legally required to do so.
Please note that any comments or information that you post on the website, including the “Sterling” community membership site on Mighty Networks and the social media pages of Jacquette M. Timmons (Facebook, Twitter and Instagram), become public and third parties may use your information. “Sterling” is not responsible for any unauthorized uses by third parties in such context. You disclose such information at your own risk.
7. Links to Other Sites
You may see advertising or other content on this website that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors or other third parties. Any products or services reached through a third-party link are subject to separate privacy policies. “Sterling” is not responsible for or liable for any content on or actions taken by such third-party websites.
8. How to Complain
We hope that we can resolve any question or concern you raise about our use of your information.
If you are covered by the General Data Protection Regulation, you may lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
9. Changes to This Privacy Notice
10. How to Contact Us
Jacquette M. Timmons
Sterling Investment Management, Inc.
30 Wall Street, Floor 8/PMB #0057, New York, NY 10005
NOTE: Jacquette M. Timmons also serves as the firm’s Data Protection Officer.
11. Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).