Last updated: 8/16/21
Stable USA Inc.’s platform provides content and data for price risk management purposes in commodities where no futures markets exist. Together with our partners, we work with eligible counterparties across the globe to help them understand and manage price risk.
Stable USA Inc. (“Stable USA Inc.”, “we”, “our” or “us”) cares about the security and privacy of the personal data that is entrusted to us.
This policy describes the Personal Data that we collect, how we use and share it, your rights and choices, and how you can contact us about our privacy practices.
Stable USA Inc. obtains Personal Data about you from our various sources. “You” may be a visitor to one of our Sites (“Visitor”), or the end customer of a Visitor entering information on Your behalf (“End Customer”). All customers interacting with the Site (directly or indirectly) will be referred to collectively as “Users”.
2. Personal Data We Collect
- Personal Data that we collect about you
Personal Data is any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP Address). In many cases, the Personal Data that you provide directly to us through our Site will be apparent from the context in which you provide the data:
When you first register for a Stable USA Inc. account on our Site we collect the following data:
- Full name
- Log-in credentials
- Position at Company
- Contact information (phone number(s) etc.)
- Company name
- Location of Company
- Turnover band
- Business type
- Commodity interest and exposures
- When you request a risk management quote from a partner, we collect the following data:
- Insurable interest (commodity, quantity history, quantity expectations)
- Confirmation of investor status, as applicable based on jurisdiction
- Prior to signing a contract with a partner, they are required by legislation to perform Know Your Customer (KYC), Anti Money Laundering (AML) and Customer Due Diligence (CDD) checks on the business, certain individuals, and End Customers, as applicable.
Please note, the level of due diligence varies from business to business and additional documents and clarifications may be required for your particular structure.
- When you respond to Stable USA Inc. emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Stable USA Inc., as well as other information you may provide during the call. If you are a Stable USA Inc. account holder or End Customer, when you contact us, we may collect additional information in order to verify your identity.
- Any payments made through the Site are done through Stripe.
In connection with fraud monitoring, prevention, detection, and compliance activities for Stable USA Inc. and its Users, we receive identity related from the following sources:
- From Customers (including through their devices (e.g. IP Addresses)) related to Customers.
- From Users about themselves and their Customers, including as collected through our Services.
- From our business partners, financial service providers, identity verification services, and publicly available sources.
This Personal Data (e.g., name, address, phone number, country) helps us to confirm identities and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by a Customer with a Stable USA Inc. User.
You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details in connection with trade shows or other events.
- Information that we collect automatically on our Sites and through marketing of our products
- Browser and device data, such as IP Address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Site you are visiting.
- Usage data, such as time spent on the Site, pages visited, links clicked, language preferences, and the pages that led or referred you to our Site.
- Online activities. We collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online services.
- We collect information when you engage with our marketing messages and when you click on links included in ads for our products. We use Google Analytics on our Site to help us analyze your use of our Site and diagnose technical issues.
3. How We Use Personal Data
- Our Services
We rely upon a number of legal grounds to enable our use of your Personal Data. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests.
Contractual and pre-contractual business relationships
We use Personal Data for the purpose of entering into business relationships with prospective Stable USA Inc. Users, and to perform the contractual obligations under the contracts that we have with Stable USA Inc. Users. Activities include:
We use Personal Data to verify the identity of our Users in order to comply with laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.
Legitimate business interests
Where permitted under applicable law, we rely on our legitimate business interests to process Personal Data about you. When we do so, we balance our legitimate interests against the interests and rights of the individuals whose Personal Data we process. The following list sets out the business purposes that we have identified as legitimate:
- Mitigate financial loss, liabilities or other harm to Customers, Users and Stable USA Inc.;
- Determine eligibility for and offer new Stable USA Inc. products and services, where applicable legislation allows;
- Respond to inquiries, send Service notices and provide customer support;
- Promote (where permitted), analyze, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
- Manage, operate and improve the performance of our Site and Services by understanding their effectiveness and optimizing our digital assets;
- Analyze and advertise our Services;
- Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
- Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business;
- Enable network and information security throughout Stable USA Inc. and our Services; and
- Share Personal Data among our affiliates for administrative purposes.
- Marketing and events-related communications
We may send you email marketing communications about Stable USA Inc. products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with applicable law, including any consent requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.
We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site Visitors.
4. How We Disclose Personal Data
Stable USA Inc. does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
- Stable USA Inc.
We share Personal Data with other Stable USA Inc. affiliated entities and service providers in order to provide our Services and for our administration purposes.
- Service providers
We share Personal Data with certain service providers subject to contract terms that limit their use of Personal Data. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, marketing service, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in Bermuda, the United Kingdom, and the United States of America.
- Business partners
We share Personal Data with third party business partners in connection with our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks, reinsurers, and insurance managers. This Personal Data is shared for the purpose of paying claims and to fulfill the schedule of services by the professional services firms with whom we partner.
- Corporate transactions
- Compliance and harm prevention
We share Personal Data as we believe necessary: (i) to comply with applicable law; (ii) to enforce our contractual rights; (iii) to protect the Services, rights, privacy, safety and property of Stable USA Inc., you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
5. Your Rights and Choices
You may have choices regarding our collection, use and disclosure of your Personal Data:
- Opting out of receiving electronic communications from us
If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you other messages in connection with providing our Services.
- How you can see or change your account Personal Data
If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by signing in to your Stable USA Inc. account or by contacting us.
- Your data protection rights
Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
- The right to request confirmation of whether Stable USA Inc. processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
- The right to request that Stable USA Inc. rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
- The right to request that Stable USA Inc. erase your Personal Data in certain circumstances provided by law;
- The right to request that Stable USA Inc. restrict the use of your Personal Data in certain circumstances, such as while Stable USA Inc. considers another request that you have submitted (including a request that Stable USA Inc. make an update to your Personal Data);
- Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
- In some cases, you may also have the right to object to the processing of your Personal Data.
- Process for exercising data protection rights
We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.
6. Security and Retention
We retain your Personal Data as long as we are providing the Services to you or our Users (as applicable). Even after we stop providing Services directly or indirectly to you, and even if you close your Stable USA Inc. account or complete a transaction with a Stable USA Inc. User, we keep your Personal Data in order to comply with our legal and regulatory obligations. We may also keep it to assist with our fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations as well as where we are required to retain the data by our contractual commitments to our financial partners. In all cases where we keep data, we do so in accordance with any limitation periods and record retention obligations that are imposed by applicable law.
7. International Data Transfers
We are a global business. Personal Data may be stored and processed in any country where we do business or our service providers do business. We may transfer your Personal Data to countries other than your own country. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. Officials (such as law enforcement or security authorities) in those other countries may be entitled to access your Personal Data.
9. Links To Other Online Services
10. Controllers and Jurisdiction-specific Provisions
Depending on the activity, Stable USA Inc. acts as a Controller and Processor.
We conform to Data Privacy Laws as applicable for the jurisdictions housing active Users. This includes country-wide laws as well as US State-specific laws
11. Contact Us