This Privacy Notice (Notice) is intended for use by individuals within the European Union to whom Stratton provides services. It gives you information about the way we collect and use personal information about you (which is known as “personal data” under data protection legislation).

You should read through this Privacy Notice to fully understand the basis upon which we collect your personal data, how we use it, where we store it and to whom it is disclosed.

Commitment to Privacy

We are committed to protecting your personal data and right to privacy. We will always keep your personal data safe and comply with applicable data protection legislation from time to time in place.

Your rights

By EU law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.

Rights	What does this mean?
1. The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this Notice.
2. The right of access	You have the right to obtain access to your personal data (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you’re aware and can check that we’re using your personal data in accordance with data protection law
3. The right to rectification	You are entitled to have your personal data corrected if it’s inaccurate or incomplete.
4. The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing	You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to object to processing	You have the right to object to processing for direct marketing (which we do only with your consent) and also to processing which is carried out for the purposes of our legitimate interests.
7. The right to lodge a complaint	You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
8. The right to withdraw consent	If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

Please see the section titled Requests to us below, for more information on how we will handle your requests to us.

Who we are

Stratton Consulting Group, LLC is the owner and operator of ils.strattonconsulting.com It is the Data Controller of the information we collect from you.

We are based in the United States and we process your data in the US. We have agreed clauses in our agreement with your employer which adequately safeguard your data when it is processed by us. Should you require any further information about these safeguards, please email dpaul@strattonconsulting.com.

What personal data do we collect about you?

We collect the personal data you provide to us as part of your registration and during your completion of the ILS survey. This personal data includes your name, email address, and the report that is generated by your answers.

How we use your personal data

We are processing your personal data to enable us to provide a report about you to your employers.

Who we share your personal data with

We share your personal data with your employer.

For the purposes set out above, your personal data may be accessible to our processors who perform certain IT business services for us. We do not share your personal data with anyone.

In addition, we may disclose your personal data:

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and
• to successors in title or replacement operators of all or part of our respective businesses.

The legal basis for us using your personal data

We process your data to enable us to perform the contract between us and you individually, or alternatively between us and your employer.

What happens if you do not provide us with the personal data we request?

If you do not provide us with your personal data, we will not be able to provide you or your employer with an ILS report about you; if you have been asked to participate in this process by your employer, you may need to resolve that with your employer.

Requests to us

We are required by law to act on requests and provide information free of charge, except where your requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

Contacting us

If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above) please send your request to dpaul@strattonconsulting.com.