Privacy Policy

Privacy Notice 

 

Last Date Modified: December 31, 2022

 

WHO IS STOA USA, INC.? 

 

Stoa USA, Inc. and its affiliated companies (together “Stoa,” “we,” and “us”) provides an online proprietary platform (‘Platform”) that enables commercial real estate investors (“Partners”) to submit single family residential properties for pricing evaluation as well as to efficiently apply for and obtain funding for the renovation of such qualified properties (each a “Property” and, collectively, “Properties”) that are then purchased by Stoa upon satisfactory completion. Stoa then sells the Properties to institutional investors and others (collectively, “Buyers”) as “rent-ready” investments. (Partners and Buyers are sometimes collectively referred to as “Customers”) 

Stoa takes the private nature of the Personal Information (defined below) we collect seriously, and we are committed to protecting it.  Therefore, we have in place controls and procedures designed to ensure that such information is managed responsibly and in accordance with applicable data protection and privacy laws (collectively, “Privacy Laws”).  

This Privacy Notice applies to Stoa’s practices where we function as a data controller (or equivalent role as described under the various Privacy Laws in our regions of operations).  It describes the categories of Personal Information that we collect and the sources of such information, how we use that Personal Information, to whom Personal Information is disclosed and sold and for what purposes, and the rights data subjects have with respect to their Personal Information. 

 

SCOPE OF PRIVACY NOTICE  

This Privacy Notice addresses our Personal Information processing practices as it relates to: (a) our corporate website (the “Website”); (b) operation of the Platform; (c) other direct interactions with individuals/corporate entities, and (d) any data that we collect from third parties. 

 

PERSONAL INFORMATION

For purposes of this Privacy Notice, “Personal Information” means any information relating to an identified or identifiable natural person.  An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  Personal Information includes information referred to as “personal data,” “personal information,” “personally identifiable information” and such similar references as codified in applicable Privacy Laws.

 

Most of the information Stoa collects pertains to commercial entities and persons associated with such entities (e.g., an officer, employee, contractor.)  Under most U.S. Privacy Laws, such information is not considered “Personal Information.”  However, certain jurisdictions (e.g., California) and jurisdictions outside the U.S. (e.g., the United Kingdom and the European Union), do consider such information to be “Personal Information,” with certain exceptions.  As a result, we consider information about an individual, in their professional capacity, to be Personal Information for purposes of this Privacy Notice.  Note, however, that the rights of a data subject with respect to Personal Information are determined by the Privacy Law of the jurisdiction in which the data subject resides.

 

HOW STOA COLLECTS AND USES PERSONAL INFORMATION 

Stoa collects Personal Information in a number of ways: (1) from Customers in connection with the establishment of an account with Stoa and our interactions with such Customers; (2) from visitors to our Website; (3) from vendors, Customers and other individuals with whom we interact in person, over the telephone, via email and other means of communication, and; (4) from third party data sources.  The table below sets forth the categories of Personal Information Stoa has collected in the preceding twelve 912) months, the sources of such information and the purpose or use for which Stoa collects Personal Information. 

 

Category of Personal Information Collected

Examples of Data Elements Collected

Categories of Sources of Personal Information

Purpose for Collection

Personal Identifiers:  

Business address

Drivers’ license number

IP address

Phone number

Email address 

Password

Bank account and other financial information

  • Customers including, without limitation, subscribers to the Platform;
  • Data brokers

None of this information is used to infer characteristics about the individual to whom it pertains:

 

  • performing services for Customers, maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying subscriber information;
  • to authenticate access to the Platform;
  • to respond to Customer inquiries and requests;
  • auditing interactions and transactions;
  • for bug and performance tracking and to optimize website and Platform performance;
  • to send Customers our newsletter and provide information about our products and services;
  • to communicate with Customers regarding events we host;
  • to request feedback regarding Customers’ experience with the business;
  • for personalized advertising and analytics.   Stoa uses advertising networks and other providers to display or to manage our advertising on other websites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to Website visitors based on their browsing activities and interests and determine the effectiveness of such advertisements.  
  • detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity;
  • short-term, transient internal use;
  • internal research for technological development;
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights; 
  • to otherwise comply with applicable law.

Full name

Home and Work Address

Date of Birth

Photograph

Personal and Business email

Personal and Business telephone number

Personal email

Social security number Driver’s license number

Citizenship status

Residency and work permit status

Gender

Race

Veteran status

Signature

Passport number 

LinkedIn URL

Twitter URL

GitHub URL

Portfolio URL

Contents of emails regarding job applicants

Bank account and other financial information

 

Any additional information provided in a cover letter and a resume/CV, including the company with which applicants are currently employed.

Job applicants

Recruiting firms

Social media sites;

Other publicly available sources

None of this information is used to infer characteristics about the individual to whom it pertains:

 

  • verifying applicant information;
  • recruiting, arranging interviews and testing, making decisions on appointment.to respond to applicant inquiries and requests;
  • entering, performing and managing employment contracts, determining the terms of an employment offer;
  • auditing interactions and transactions;
  • complying with laws and regulations (e.g., anti-discrimination laws, and global migration), preparing for and acting in relation to inquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation;
  • short-term, transient internal use;
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights; 

First and last name

Email address

Password

Phone number

Company name

Other Website visitors:

  • to respond to inquiries and requests;
  • for bug and performance tracking and to optimize website and Website performance;
  • to send visitors our newsletter and provide information about our products and services;
  • to communicate with visitors regarding events we host;
  • to request feedback regarding visitors’ experience with the business;
  • detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity;
  • short-term, transient internal use;
  • internal research for technological development;
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights; 
  • to otherwise comply with applicable law.
  • for advertising and analytics. Stoa uses advertising networks and other providers to display or to manage our advertising on other websites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to Website visitors based on their browsing activities and interests and determine the effectiveness of such advertisements.  

First and last name

Email address

 

Phone number

Company name

Others with whom we interact in person, on the phone or through some other medium.

  • performing services for Customers, maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying Customers information;
  • to respond to inquiries and requests;
  • auditing interactions and transactions;
  • to send our newsletter and provide information about our products and services;
  • to communicate regarding events we host;
  • to request feedback regarding experience with the business;
  • protecting against malicious, deceptive fraudulent or illegal activity;
  • short-term, transient internal use;
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights; 
  • to otherwise comply with applicable law.

Electronic Network Activity:  

 

 

Unique device identification numbers;

Operating system and version;

Performance data and browsing history;

Time spent per visit;

Cumulative time spent across all usage;

Frequency of usage;

Features used;

Buttons clicked;

Actions taken and frequency of each;

Ad tracking codes

Subscribers to the Platform and Website visitors:

  • for bug and performance tracking and to optimize Website and Platform performance.
    • auditing interactions and transactions;
    • detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity;
    • short-term, transient internal use;
    • performing services for subscribers, maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying subscriber information, processing payments;
    • internal research for technological development;
    • to respond to or defend against subpoenas, court orders, or other legal process; 
    • to establish or exercise our legal rights; 
    • to otherwise comply with applicable law.
    • to identify the performance of ads that Stoa places on third party sites to drive traffic to our Website;
  • for advertising and analytics. Stoa uses advertising networks and other providers to display or to manage our advertising on other websites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to Website visitors based on their browsing activities and interests and determine the effectiveness of such advertisements.  Please see our Cookie Policy for additional information.

Commercial Information:  

Records of loans requested and received from Stoa;

Partners

  • performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling transactions;
  • verifying information;
  • complying with laws and regulations 
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights;
  • auditing interactions and transactions;
  • protecting against malicious, deceptive fraudulent or illegal activity
  • for personalized advertising and analytics.   Stoa uses advertising networks and other providers to display or to manage our advertising on other websites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to Website visitors based on their browsing activities and interests and determine the effectiveness of such advertisements.  

Records of Properties purchased from Stoa

Buyers

  • performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling transactions;
  • verifying information;
  • complying with laws and regulations 
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights;
  • auditing interactions and transactions;
  • protecting against malicious, deceptive fraudulent or illegal activity;
  • for personalized advertising and analytics.   Stoa uses advertising networks and other providers to display or to manage our advertising on other websites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to Website visitors based on their browsing activities and interests and determine the effectiveness of such advertisements.  

Real property ownership information;

Mortgage information;

Real property transaction information;

Foreclosure information

Data Brokers

  • performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling transactions;
  • verifying information;
  • lead generation;
  • complying with laws and regulations 
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights;
  • auditing interactions and transactions;
  • protecting against malicious, deceptive fraudulent or illegal activity

Professional or employment-related information:  

Tax ID Number; 

Name of the company with which individuals are employed;

Role with company  

Customers including, without limitation, subscribers to the Platform:  

  • performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying information;
  • to respond to inquiries and requests;
  • auditing interactions and transactions;
  • for bug and performance tracking and to optimize website and Platform performance;
  • to send our newsletter and provide information about our products and services;
  • to communicate regarding events we host;
  • to request feedback regarding experience with the business;
  • detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity;
  • short-term, transient internal use;
  • internal research for technological development;
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights; 
  • to otherwise comply with applicable law.

Current and prior employment history;

Any other information provided in a cover letter and a resume/CV

Job applicants

Recruiting firms

Social media sites

  • verifying applicant information;
  • recruiting, arranging interviews and testing, making decisions on appointment.to respond to applicant inquiries and requests;
  • entering, performing and managing employment contracts, determining the terms of an employment offer;
  • auditing interactions and transactions;
  • complying with laws and regulations (e.g., anti-discrimination laws, and global migration), preparing for and acting in relation to inquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation.
  • short-term, transient internal use;
  • to respond to or defend against subpoenas, court orders, or other legal process; 
  • to establish or exercise our legal rights;
 

Data Collection Through Cookies

When you visit our Website, including when using our Platform, our goal is to make the experience simple and effective.  To that end, we use text files, known as cookies, to track information about your use of our Website. A cookie is a text file that a website stores on a visitor’s computer to enable recognition of that visitor’s computer each time he/she/they return.  As you navigate through and interact with our Website, we will automatically collect certain information about your equipment, browsing actions and patterns using these cookies. This may include information about your connectivity, your IP address and browser information, location data, logs and other communication data, and the resources that you access and use on the Website. The information we collect helps us to improve our Website and deliver better and more personalized content and services, enables us to estimate our audience size and usage patterns and recognize when you return to our Website.  

 

Most web browsers automatically accept cookies, but if you prefer, you can change your browser settings to prevent that or to notify you each time a cookie is set. Please note however that by blocking or deleting cookies, you may not be able to take full advantage of our Website or Platform.  Please refer to our Cookie Policy for more information on the specific cookies we use, the purpose for such cookies and how you can indicate your choices regarding placement of cookies.

 

STOA’S DISCLOSURE, SALE AND SHARING OF PERSONAL INFORMATION

Personal Information Disclosed to Third Parties for a Business Purpose

Stoa does not sell to or share your Personal Information with third parties

There are, however, certain circumstances in which we may disclose your Personal Information with trusted third parties in order to improve, protect and support our business.  For instance, Stoa may disclose Personal Information to: (i) our subsidiaries; (ii) affiliated companies; (iii) service providers (e.g., hosting providers, title companies, property inspectors, property preservation providers, payment processors, business advisors, auditors, etc.); and (iv) any potential purchasers or investors in the business. In addition, Stoa may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with a legal obligation; (ii) protect and defend our rights or property; or (iii) protect the rights, property, or safety of our Customers, visitors to our Website, or the public.

 With respect to disclosures of Personal Information to third parties that do not qualify as related entities or service providers, our practices are described in the chart below.   

 

Category of Personal Information 

Is the Personal Information Disclosed to Third Parties for a Business Operations Purpose

Category of Third Parties to Whom Disclosed

For what Purpose

Personal Identifiers

Y

Subsidiaries; Affiliates; Service Providers

  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance;
  • security; and
  • debugging

Electronic Network Activity 

Y

Subsidiaries; Affiliates; Service Providers

  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance;
  • security; and
  • debugging

Characteristics of protected classification and other sensitive information:  

N

   

Commercial Information

Y

Subsidiaries; Affiliates; Service Providers

  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance;
  • security; and
  • debugging

Professional or Employment-related Information

Y

Subsidiaries; Affiliates; Service Providers

  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance; and
  • security
 

Personal Information Sold to or Shared With Third Parties

 

Stoa does not sell to or share your Personal Information with third parties

 

Category of Personal Information 

Is Personal Information Sold to Third Parties 

Category of Third Parties to Whom Sold

For what Purpose

Personal Identifiers

Y

Service Providers

  • to assist Stoa in advertising our services;
  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance;
  • security; and
  • debugging

Electronic Network Activity 

Y

Service Providers

  • to assist Stoa in advertising our services;
  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance;
  • security; and
  • debugging

Characteristics of protected classification and other sensitive information:  

N

   

Commercial Information

Y

Service Providers

  • to assist Stoa in advertising our services;
  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance;
  • security; and
  • debugging

Professional or Employment-related Information

Y

Service Providers

  • auditing interactions and transactions;
  • processing interactions and transactions;
  • managing interactions and transactions;
  • performing services;
  • quality assurance;
  • security; and
  • debugging
 

Stoa does not share Personal Information with third parties for use by the third parties in their own marketing.

Disclosure to Service Providers

Stoa requires third party service providers with whom we share Personal Information to process Personal Information only as allowed in our contract with such third party service providers.  We ensure that any third party service provider with whom we share Personal Information is subject to privacy and security obligations consistent with this Privacy Notice and applicable laws.

 

HOW WE PROTECT PERSONAL INFORMATION

The security of your Personal Information is important to us.  We maintain industry standard physical, technical and administrative safeguards designed to protect your Personal Information from unauthorized access, use, disclosure, and destruction.  Although we take reasonable steps to safeguard Personal Information, we make no warranty, express, implied or otherwise, that we will prevent such.

We update and assess our security controls on a regular basis.  We also train our personnel about the importance of confidentiality, security and consumer privacy and limit our personnel’s access to Personal Information to only those employees who require access based on their job duties.

Electronic Personal Information, including the Personal Information about visitors to our Website and Personal Information submitted by our Platform users regarding their account and log-in information, is stored on systems in an enterprise third party cloud provider in the United States. 

 

HOW LONG DO WE RETAIN PERSONAL INFORMATION?

Information about Customers:  Stoa retains Personal Information collected from Customers for upwards of fifteen (15) years.  

Website Visitor Information:  We retain Personal Information about those who visit the Website as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.

Job Applicant Information:  We retain Personal Information obtained from our vendors for as long as our company retains a relationship with such vendors and for a period of time afterwards in order to satisfy legal, accounting and policy obligations.

 

A NOTE ABOUT CHILDREN’S PERSONAL INFORMATION 

Neither the Platform nor the Website is marketed to, and neither is intended for use by, children.  Therefore, Stoa does not knowingly collect any Personal Information from children under the age of 17. If you know or believe that such information has been provided to us, please contact us at [email protected].  If we become aware that we have collected Personal Information about a child under the age of 17, we will delete it. 

 

YOUR RIGHTS TO ACCESS

We will comply with all reasonable requests from you to correct, amend, or delete the Personal Information we have about you, and will provide you access to your Personal Information. There may be limits to the amount of information we can practically provide. For example, we may limit an individual’s access to Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy or where doing so would violate other’s rights.  You may contact us at [email protected].

 

IF YOU ARE A CALIFORNIA RESIDENT

Stoa does not currently loan funds for, or purchase, Properties located in California.  However, it is possible that Customers with whom we interact are California residents.  For those California residents, in addition to the rights discussed above, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, the “Act”), as it relates to the Personal Information Stoa collects about you:

 
  • Right to Know Before Collection of Personal InformationAt or before the point your Personal Information is collected, Stoa must inform you of the following:
 
  • The categories of Personal Information to be collected and the purposes for which they are collected or used;
  • The categories of Sensitive Personal Information to be collected and the purposes for which the information is collected and used.
  • Whether Personal Information and/or sensitive Personal Information is sold or shared.
  • The length of time Stoa intends to retain each category of Personal Information (including Sensitive Personal Information) collected or, if that is not possible, the criteria used to determine that period.  
 

Note that Stoa does not knowingly collect, sell or share the Personal Information of individuals under the age of 17. 

 
  • Right to Know What Personal Information Is Being Collected and Right to Access:  California residents have the right to request disclosure of the following information, up to twice in a twelve-month period, from Stoa:
 
  • the categories and specific pieces of Personal Information that Stoa has collected about you; 
  • the categories of sources from which that Personal Information is collected; 
  • the business or commercial purpose for collecting, selling or sharing that Personal Information, and; 
  • the categories of third parties to whom Stoa discloses Personal Information.  
 

Before providing such information to you, Stoa must verify your identity.  We will utilize the information that you submit with your request in order to do so and to locate any information that we maintain about you and for no other purpose.

 
  • Right to Know About Personal Information Sold or SharedStoa does not sell or share Personal Information.
 
  • Right to Request Deletion:  California residents have the right at any time to request that Stoa delete any Personal Information that we collected directly from them.  Stoa collects Personal Information directly from consumers as described in the Section titled “How Stoa Collects and Uses Personal Information” above.  The obligation to delete Personal information upon request is not absolute.  The law allows businesses to retain Personal Information for certain purposes, such as the need to retain the information to service a transaction you have with us, even when a deletion request is received.  In addition, before deleting information in response to a request, Stoa must verify the requesting resident’s identity. 
 
  • Right to Correct Inaccurate Personal Information:  California residents have the right to request at any time the correction of inaccurate Personal Information that Stoa maintains about the requesting resident.  Before correcting Personal Information in response to  a request, Stoa must verify the requesting resident’s identity.
 
  • Right to Opt-out of the Sale or Sharing of Personal Information: California residents have the right to direct a business that sells and/or shares Personal Information to third parties to stop doing so).  Stoa does not sell or share Personal Information.  As a result, Stoa is not required to post a Notice of Right to Opt-out nor a “Do Not Sell Or Share My Personal Information” link.  
 
  • Right to Limit Use and Disclosure of Sensitive Personal Information:  California residents have third right at any time to direct companies to limit the use of their sensitive Personal Information to that necessary to provide the services requested by such resident and to those purposes otherwise allowed by California law.  Stoa only uses and discloses sensitive personal information for purposes permitted under California law.  As a result, Stoa is not required to post a Notice of Right to Limit.  Nor is Stoa required to comply with a request to limit.
 

Right Non-Discrimination:  California law prohibits Stoa from discriminating or retaliating against a California resident based on such resident’s exercise of the privacy rights described herein.  For example, Stoa cannot deny a loan or provide a different level or quality of service as a result of a California resident exercising their rights.

 

 

Method to Submit Requests:

If you are a California resident and wish to exercise any of the rights listed above, please provide your name, phone number, and any other identifiers that you think will help us to verify you using one of the methods reflected below.  Upon receipt of a request to know, to delete, or to correct (collectively, “Data Request”), Stoa will use the information you provide in the request to verify your identity. Stoa may occasionally request additional information in certain circumstances to assist in facilitating verification.  Any information received by Stoa in response to a request for additional information will  be held strictly in confidence, used only for the purposes of processing your request and in accordance with applicable data privacy laws and regulations. 

 
  • To submit a Data Request, you may call us at our toll-free number, 1-800-991-3591, or by clicking here.

California law allows you to designate an agent to submit a request to exercise any of the above rights on your behalf.  To have an authorized agent submit a request on your behalf, the authorized agent must provide Stoa with proof that you gave the agent signed permission to submit the request.  We may also require you to verify your identity or confirm that you provided the authorized agent with power of attorney under the Probate Code.  

 

Responses To Data Requests

We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by email.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. 

Upon verifying your identity and confirming there are no applicable exemptions to deny the request, we will delete your personal information from our records and direct any service providers to do the same. 

 

IF YOU LIVE IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM OR SWITZERLAND (collectively, “Europe”) 

Stoa complies with the EU General Data Protection Regulation 2016/679, the UK Data Protection Act of 2018 and the Swiss Data Protection Act of 2020 (collectively, “GDPR”) with respect to the protection of individuals when processing their Personal Information and the free movement of such Personal Information.  

 

Under the GDPR, you have the following rights. 

 
  • Right of Access:  You have the right to ask us for copies of your Personal Information. The law provides for some exemptions, which means you may not always receive all the Personal Information we process.
  • Right to RectificationYou have the right to ask us to rectify Personal Information you think is inaccurate. You also have the right to ask us to complete Personal Information you think is incomplete. 
  • Right to Restrict Processing:  You have the right to ask us to restrict the processing of your Personal Information in certain circumstances.
  • Right to Withdraw ConsentYou have the right to revoke your consent to our processing of your Personal Information at any time by contacting us at [email protected].  Withdrawing consent will not affect the lawfulness of the processing performed based on your consent before its withdrawal.
  • Right to Erasure:  You have the right to ask us to erase your Personal Information in certain circumstances.
  • Right to Data PortabilityThis only applies to Personal Information you have given to us and that is held electronically. You have the right to ask that we transfer this information from Stoa to another organization or give it to you. 

You may contact us at [email protected] if you wish to make a request with respect to exercising your rights above.  You are not required to pay any charge for exercising your rights. We have one month to respond to you.  You may also contact the relevant supervisory authority to lodge a complaint related to our handling of your Personal Information.  However, we invite you to give us a chance to resolve the situation directly with you. Your privacy is important to us, and we will do our best to address any concerns.

Stoa does not lend funds for Properties located outside of the continental United States.  However, we do have Customers who are residents of other countries and our Website is available globally.  Please note that our computer systems are based in the United States, which means Personal Information we collect will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union.  For transfers to the United States, we will either rely on a derogation applicable to the specific situation (e.g. consent or if the transfer is necessary to perform our contract with the data subject) or implement the Standard Contractual Clauses adopted by the European Commission and/or an International Data Transfer Addendum with respect to transfers outside of the United Kingdom.

The legal bases for processing your Personal Information include one or more of the following depending on the circumstances:

  • To comply with contractual obligations or to take steps at your request before entering into a contract. When you subscribe to the Service, we will process your Personal Information in order to provide the Service to you and answer your requests.  
  • As a result of your consent.  In certain cases, you consent to the processing of your Personal Information by us (e.g., when you submit the information via the Website or use our Service.)  When consent is the basis on which we process your Personal Information, we will inform you if we need to carry out further processing for purposes other than those for which you provided us with your consent and obtain your further consent. You may withdraw your consent at any time. For further information on the right of withdrawal, please contact Stoa at: [email protected]
  • Within the scope of a legitimate interest. On occasion, where we have a legitimate interest to process your Personal Information, we may not need your consent to do so, however, we must inform you that we do this.  Examples of a legitimate interest include:
  • The analysis and optimization of the Website;
  • Ensuring IT security and the operation of Stoa’s technology;
  • Prevention and investigation of criminal acts.
  • On the basis of Stoa’s legal obligations or in the public interest. In some cases the processing of your Personal Information will be necessary for us to fulfill legal or public interest obligations.

If Stoa uses email prospecting, we first obtain the consent of the individual, unless the recipient is already a Customer and the email involves products similar to those we already provide to such Customer.  In such instances, the legal basis of the processing is the legitimate interest of Stoa, namely to promote our products to our Customers.  When Stoa sends commercial solicitations to Customers by email regarding products other than those already provided to such Customers, the legal basis of the processing is consent.

 

You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at: [email protected].  

 

HOW LONG DO WE RETAIN PERSONAL INFORMATION?

Information about Customers:  Stoa retains Personal Information collected from Customers for upwards of fifteen (15) years.  

Website Visitor Information:  We retain Personal Information about those who visit the Website as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.

Job Applicant Information:  We retain Personal Information obtained from our vendors for as long as our company retains a relationship with such vendors and for a period of time afterwards in order to satisfy legal, accounting and policy obligations. 

 

CHANGES TO THIS PRIVACY NOTICE

As we evolve, we may update this Privacy Notice to align with changes in the Platform, our business and/or Privacy Laws.  The Effective Date at the beginning of this Privacy Notice will reflect the last date on which the Privacy Notice was updated.  We recommend that you periodically review the Privacy Notice to stay informed of changes. We will ask for your consent to such changes if required by Privacy Law.  The same is true with respect to Personal Information that we collect via email, snail mail and other communication methods. If you disagree with the Privacy Notice, please email us at [email protected]  and stop using the Website. 

 

 

HOW TO CONTACT US

If you have any questions about this Privacy Notice or wish to exercise your rights hereunder, please contact us at [email protected] .  

 

Written inquiries can be sent to: 

 

Stoa USA, Inc.

Attn: Director of Security

2394 E Camelback

Suite 200

Phoenix, AZ 85016

1-800-991-3591