Privacy Policy

Stone Harbor Privacy Policy

We ask that you read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us. We may need to make changes to our Privacy Policy; so please check our website for updates from time to time.

About this Privacy Policy

This Privacy Policy applies when you visit our website www.shipemd.com. It also applies where we are in contact with you in other ways including in your capacity as an individual or as director, partner, employee or other representative of a company or other organization.

This Privacy Policy applies to Stone Harbor Investment Partners and its subsidiaries worldwide (“Stone Harbor”). Our UK affiliates are registered with the UK Information Commissioner’s Office (“ICO”).

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact:

Stone Harbor Investment Partners Attn.: Legal Department 31 West 52nd Street, 16th Floor New York, New York 10019

Information we collect

You may provide us with personal data when you are introduced to us, when we meet you in person, or when we are in contact by phone, email, via our website or otherwise.

The categories of personal data we collect include:

information about who you are (e.g., first and last name, contact details, company name)
information about your contact with us (e.g., meetings, phone calls, emails / letters)
information if you visit one of our offices (e.g., visual images collected via closed circuit television)
identifying information that you provide to Stone Harbor to gain electronic access to our client portal
information that is automatically collected via cookies when you visit our website or client portal. Please refer to the section below for more information on cookies.

We may collect your personal information directly from you and from a variety of sources, including:

an application form for a product or service
phone conversations with us (including recorded phone lines when speaking to certain Stone Harbor personnel)
emails or letters you send to us
meetings with one of our representatives
registering for one of our events (e.g., webinars and seminars)
our online services such as websites and client portals

We may also collect personal information about you from places such as business directories and other commercially or publicly available sources (e.g., to check or improve the information we hold (like your address), to acquire alternate contact information if we are unable to contact you directly, or, if applicable, to assist us in our ‘know your client’ obligations.)

How we use your information

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information where:

you have given us your permission to send you information, white papers, announcements and other communications concerning Stone Harbor, products and services offered by Stone Harbor, or your account.
it is necessary to provide the product or service that we provide to you or the entity that you represent
it is necessary for us to meet our legal or regulatory obligations (e.g., to send you client reports and to tell you about changes to policies or terms and conditions)
it is in the legitimate interests of a third party
to enforce terms and conditions and any contracts entered into with you or an entity that your represent
to administer our website or client portal

If you do not wish for us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

Sharing your personal data

We do not share your personal data with third parties except as provided in this Privacy Policy. We may share your information with the following third parties:

affiliates of Stone Harbor
companies we have chosen to support us in the delivery of the products and services we offer to you and other clients (e.g. consultants or technology companies; and companies who can help us in our contact with you, for example a transactional email platform)
our regulators and Supervisory Authority (e.g. the Securities and Exchange Commission, the Financial Conduct Authority (FCA), the ICO)

In addition, Stone Harbor may disclose information about you in the following circumstances:

if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation
if necessary to protect the vital interests of a person
to enforce or apply our terms and conditions or to establish, exercise or defend the rights of Stone Harbor, our staff and representatives, clients or others

Where your information is processed

The majority of your information is processed in the United States and the United Kingdom. Depending on the products or services that we provide to you, certain information may also be processed in the European Economic Area (EEA).

Security of your information

Stone Harbor has implemented industry standard physical and procedural security controls to protect your information. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations. This includes encryption, firewalls, access controls, policies and other procedures to protect information from unauthorized access.

Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorized disclosure of personal data.

Despite these precautions, however, Stone Harbor cannot guarantee the security of information transmitted over the Internet, or that unauthorized persons will not obtain access to personal data. In the event of a data breach, Stone Harbor has put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.

How long we keep your personal data

Your personal data will not be kept for longer than is necessary for the purposes for which it was ollected and processed and for the purposes of satisfying any legal, accounting, or reporting requirements.

Your rights

Right of access and accuracy: You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold about you, you may make a data subject access request (DSAR). If your personal information is inaccurate or incomplete, you have the right to request that it be rectified.

Right to object: You have the right to object at any time to our processing of your personal data where it is based on our legitimate interests or it is used for direct marketing purposes.

Right to be informed: You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with.

You also have the right to: request the erasure of your personal data (“right to be forgotten”) if there is not a compelling reason for Stone Harbor to maintain such data, and to restrict the processing of your personal data to processing in certain circumstances.

You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting us as provided in the “Contact Us” link on our website.

How we use cookies and monitor use of our website

Stone Harbor does not monitor or collect any personally identifiable information from visitors to our website. Stone Harbor may, however, track the number of users who visit the public areas of the website. Stone Harbor also may record the location of a user’s computer on the Internet for systems, administrative and troubleshooting purposes and to report aggregate information. Stone Harbor uses various technical means, including “cookies,” to collect and store information about a user’s Internet connection when a user visits our website. Cookies are data elements that the website sends to a user’s browser. Stone Harbor uses cookies to measure the number of visitors to different parts of the website. This information helps Stone Harbor to improve the website and make it more useful to visitors. If you would prefer not to accept cookies from the website, you may set your browser accordingly. If you choose to disable cookies in your browser, you can still access most of the website. Stone Harbor may use other methods now or in the future to accomplish the goals of collecting technical and navigation information about the website.

How we receive information and monitor use of our client portal

To access Stone Harbor’s client portal, a user must provide a user name and password. The identifying information that a user provides to Stone Harbor to gain access, including name and email information, together with any additional information a user provides, may be processed and stored by Stone Harbor. Stone Harbor may disclose a user’s personal information (i) to maintain or administer a user’s account, (ii) to respond to a user’s requests, (iii) to conform to necessary or advisable legal or regulatory requirements, (iv) to comply with legal process, and/or (v) to protect the rights, safety, or property of Stone Harbor, the client portal, the public or others.

Complaints

If you have any questions or complaints regarding our Privacy Policy or practices, please contact us as provided in the “Contact Us” link on our website.

European Union and United Kingdom users: You have the right to make a complaint at any time with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is ICO who can be contacted at https://ico.org.uk or telephone on 0303 123 1113.