privacy

Stetson Family Office Privacy Policy  Revised 11-02-18 
Our business is built upon trust. Stetson Family Office considers our client's trust in the protection of corporate and personal data (data privacy) to be of great value. Furthermore, Stetson Family Office abides to all applicable data protection acts and endeavors to continuously improve data protection. 

This website provides information on various companies, in particular on Stetson Family Office and its affiliated organizations such as GlobalFamilyOfficeBioforum, GlobalBetterHealth, Healthcare Impact Foundation and NetCapital-GFOB Portal. For the purposes of this Privacy Statement “Stetson Family Office” means Stetson Family Office, 505 Park Avenue, 4th Floor, New York, New York 10022. More information is available upon request. This company is the responsible data controller for this website.

TABLE OF CONTENTS 
 1. Operation of the website 
 2. Processed data 
 2.1 Data you enter 
 2.2 Automatically collected data 
 3. Website analytics 
 3.1 General 
 3.2 Google Analytics 
 4. Email newsletter 
 5. External service providers 
 6. Retention periods 
 7. Your rights 
 8. Data protection officer of Stetson Family Office and Essentials in Education 

1. OPERATION OF THE WEBSITE 
Stetson Family Office processes your personal data to present the information that is available on this website and to provide the services offered on this website. 

Unless it is explicitly stated otherwise in the following sections the legal basis for this processing of data is Article 6(1)f) of the General Data Protection Regulation (GDPR), i.e. a balancing of interests – based on Stetson Family Office’s legitimate interest to provide this website and the services offered on it to internet users. 

2. PROCESSED DATA 

2.1 Data you enter 
For the purposes described above Stetson Family Office particularly uses any data you may enter on this website (e.g. using a contact form, or when subscribing to an email newsletter). Stetson Family Office processes this data you have entered to handle and to answer your request. 

2.2 Automatically collected data 
To present the right information to you on this website Stetson Family Office also processes the following data: 

 The address of the web page on this website you visit 
 The address of the web page you visited immediately before, if any (the “referrer”) 
 Date and time of your visit 
 Properties of your device, particularly its operating system, the browser you use and your browser’s display window size 
 Your device’s IP address in the internet 
 Randomly assigned ID numbers, which Stetson Family Office and third parties working for Stetson Family Office on your device. 

 With these ID numbers Stetson Family Office and the service providers working for Stetson Family Office and Essentials in Education can recognize your device. This makes it possible to link your current website visit to your previous website visits. Technically these ID numbers are stored in so-called “cookies” on your device. 

If you do not want Cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some Cookies and to alert you when a Cookie is placed on your device. For further information about how to do so, please refer to your browser ‘help’ / ‘tool’ or ‘edit’ section or see www.allaboutcookies.org 

3. WEBSITE ANALYTICS 

3.1 General 
Stetson Family Office strives to present the most relevant information to the users of this website. Stetson Family Office therefore uses tools to measure how this website is being used. With the help of these tools Stetson Family Office particularly collects the following kind of information: 

 On which links on other websites do users click to get to this website? 
 Which subpages of this website are visited when, how often, and in which order? 
 Which information do the website users look for? 
 On which links or offers do the website users click? Based on these kinds of information Stetson Family Office creates statistics which help to answer the following questions: 
  Which pages of the website are particularly attractive for the users? 
 Which kinds of information are most interesting for the users? 
 Which offers should Stetson Family Office make to its users? 
 For these purposes Stetson Family Office particularly uses the automatically collected data described in Section 2.2 above. The data are always stored pseudonymously (i.e. under a randomly assigned ID number). 

The legal basis for this processing of data is Article 6(1)f) GDPR (balancing of interests, based on Stetson Family Office’s legitimate interest to tailor the website to its users’ interests and needs). 

3.2 Google Analytics One of the tools used is Google Analytics, a web analytics service provided by Google, Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA, hereinafter referred to as “Google”). 

Google Analytics uses the “cookies” mentioned above in section 2.2. Your browser transmits the information created with the help of these cookies on your use of this website to Google servers in the USA, where they are stored for up to 14 months. Currently there is no decision of the EU Commission that the USA generally provides an adequate level of protection for personal data. Google undertakes, however, to comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries. More information in this regard is available here: https://support.google.com/analytics/answer/7105316?hl=en 

More information on the handling of user data within Google Analytics is available in Google’s privacy notice at https://support.google.com/analytics/answer/6004245?hl=en 

You can prevent the collection and the transmission to Google of data regarding your website use (incl. your IP address) as well as Google’s processing of such data by downloading and installing the browser plugin available here: https://tools.google.com/dlpage/gaoptout?hl=en 

4. EMAIL NEWSLETTER 
You can subscribe to a regular email newsletter and to other emails with product and service information of the Stetson Family Office and Essentials in Education’ group of companies. Sender of the emails can be the following companies of Stetson Family Office group: 

1. Global Better Health 
2. Global Family Office Bioforum 
3. Healthcare Impact Foundation 
4. Netcapital-GFOB Portal 

Stetson Family Office may transfer your contact data to the other senders to the extent this is necessary for sending their emails. 

The legal basis for the corresponding processing of data is Article 6(1)a) GDPR together with your consent. 

You can withdraw your consent and unsubscribe from the newsletter at any time. The easiest way to do that is by clicking on the “unsubscribe” link that is provided in every email. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Otherwise, you consent to the automatically collected data described in section 2.2 above when you subscribe to the newsletter on the website and you click on the confirmation link in the email that Stetson Family Office sends to you to verify your email address. 

You consent to the Stetson Family Office having these data as long as you receive the newsletter and thereafter for up to three more years (beginning at the end of the year in which you unsubscribed from the newsletter). Stetson Family Office stores the content of the email messages sent to or received from you in accordance with the statutory retention period under trade and tax laws, which is usually six years (beginning at the end of the year in which the email was sent or received). 

Stetson Family Office stores the fact of your consent as well as its details, i.e. the automatically collected data described in section 2.2 above when 

5. EXTERNAL SERVICE PROVIDERS 
Stetson Family Office uses various external services providers to operate this website (e.g. data center operators or newsletter service providers). To the extent it is necessary these service providers also process personal data. Stetson Family Office and Essentials in Education diligently selects and supervises its service providers. They process the data only in accordance with Stetson Family Office and Essentials in Education’ instructions and are also bound by this privacy statement. 

6. RETENTION PERIODS 
Stetson Family Office stores personal data only as long as it is necessary for the purposes described herein, or as long as it is necessary to comply with statutory retention periods. Unless it is stated otherwise herein the data you have entered pursuant to section 2.1 above will therefore not be retained for longer than the statutory retention period of six years which may apply pursuant to trade and tax laws. Unless it is stated otherwise herein the automatically collected data pursuant to section 2.2 will be deleted or anonymized after one week at the latest. 

7. YOUR RIGHTS 
You also have the right to receive from Stetson Family Office stores the personal data concerning you which you have provided to Stetson Family Office and Essentials in Education, in a structured, commonly used and machine-readable format. You have the right to transmit (or have transmitted) those data to another controller. 

You also have the right to lodge a complaint with the competent supervisory authority for data protection matters. 

8. DATA PROTECTION OFFICER OF STETSON FAMILY OFFICE 
For general questions or suggestions with regard to data protection please contact Stetson Family Office data protection officer by postal mail to the Stetson Family Office address stated above or via email to chuck@stetsonfamilyoffice.com.
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