THE STERLING MANHATTAN PRIVACY AND DATA POLICY
STERLING MANHATTAN and its holding company TIMESTWO INVESTMENTS (herby known as SM and X2) are committed to maintaining the trust and confidence of visitors to its website and anyone interacting with us online and via email/email forms. In particular, we are committed to safeguarding the privacy of any data collected from those visiting our website.
Personal Data means data about a living individual who can be identified from that data.
The User is the individual using the Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
The Data Subject is any living individual who is the subject of Personal Data.
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on a User’s device.
Data Controller means a person who (either alone or jointly) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Information Collection And Use
SM and X2 collect different types of information. This is for various purposes to provide a service to you and improve the SM website.
Types of Data Collected
While using the SM website, you may be asked to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This may include:
- Email address;
- First name and last name;
- Cookies and Usage Data.
Your Personal Data may be used to contact you via email or with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email that is sent or by contacting us.
Information about how the website is accessed and used may also be collected. This may include information about your computer and about your visits to and use of this website (including your IP address, geographical location browser type and version, operating system, referral source, length of visit, page views and website navigation paths) and other diagnostic data.
Tracking & Cookies Data
Cookies and similar tracking technologies are used to track the activity on the website and hold certain information.
Examples of Cookies in use:
- Session Cookies. Session Cookies to operate the Service;
- Preference Cookies. Preference Cookies to remember your preferences and various settings;
- Security Cookies. Security Cookies for security purposes.
What are your choices regarding cookies?
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
Use of Data
We use the collected data for various purposes:
- To provide and maintain the website;
- To notify you about changes to the website and associated services;
- To allow you to participate in interactive features of the website when you choose to do so;
- To provide customer support;
- To gather analysis or valuable information so that the website can be improved;
- To monitor the usage of the website;
- To detect, prevent and address technical issues.
Retention of Data
SM and X2 will also retain Usage Data for internal purposes. Usage Data is generally retained for a shorter period of time except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United Kingdom and process it here.
Security Of Data
The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Disclosure Of Data
The SM and X2 may disclose your Personal Data in the good faith that such action is necessary to:
- To comply with a legal obligation;
- To protect and defend the rights or property of the SM and X2;
- To prevent or investigate possible wrongdoing in connection with the Service;
- To protect the personal safety of users of the Service or the public;
- To protect against legal liability.
We may employ third party companies and individuals to facilitate our Service to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
When you visit our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as numbers of visitors to various parts of the site. This information is only processed in a way which not does not identify anyone. We do not make, and do not allow, Google to make any attempt to find out the identities of those visiting our website. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Social Media Sharing
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Access to your Personal Information
Under GDPR, you have the right to view, amend or delete the personal information that we hold on you. Please email your request to
Please note that we may ask you to verify your identity before responding.