Stout Risius Ross, LLC (and all affiliates and subsidiaries, collectively "Stout"), is committed to complying with the applicable data privacy and security requirements in the countries in which it operates. Stout complies with internationally recognized standards of privacy protection, and with various privacy laws globally including, but not limited to, the EU General Data Protection Regulation (GDPR). This Privacy Policy applies when providing valuation advisory, transaction opinions, investment banking, dispute consulting, management consulting, or other services (the "services") to its customers.

Who is Collecting Data

Data will be collected by Stout Risius Ross, LLC (and all affiliates and subsidiaries, collectively "Stout").

Data We Collect

Stout collects the following categories of personal data:

Contact data: We may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients or potential clients. For example, contact details of individuals who work for or on behalf of the clients, in order to carry out the client’s engagement with Stout.

Services data: Personal data may be provided to us by clients to the extent required to perform the services. Stout may also acquire personal data from a third party at the direction of our client as required to perform services.

Marketing information: We may collect information to respond to inquiries regarding our products and services or to provide you with information, reports, or updates.

Website visitor information: when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services. Please see our Terms of Use and Cookies Policy for additional information.

Clients and other Third parties who provide personal information to Stout must do so in compliance with applicable data privacy regulations.

Processing of Personal Data

We collect personal data to offer and administer our services and products. These include valuation advisory, transaction opinions, investment banking, dispute consulting, and management consulting services.

The data you provide to us will be processed in accordance with the purposes specified in this policy, namely:

• To provide the products or perform the services requested by clients and individuals pursuant to a letter of engagement, statement of work, or similar (where the processing is necessary for our legitimate business interests in conducting and managing our business)
• To provide the products or perform the services requested by clients and individuals using our website or web applications (where the processing is necessary for our legitimate business interests in conducting and managing our business)
• For complying with obligations provided by laws, current regulations and European legislation (e.g. tax regulations) (where processing is based on a legal obligation)
• For legitimate business purposes to advise you through e-mail, phone call, electronic communication, or postal mailings, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you (where the processing is necessary for our legitimate business interests)
• For marketing purposes. For example, we may use your information to further discuss your interest in the Services and to send you information regarding Stout promotions, events, products or services.
  • If you are located in the EU, we will only send you marketing communications and updates about our products, services and events with your prior consent. You can withdraw your consent at any time.
  • If you are not located in the EU, you may opt-out of receiving marketing communications and updates at any time.
  • You can manage your receipt of marketing and non-transactional communications by clicking on the «unsubscribe» link located on the bottom of Stout’s marketing emails. Additionally, you may send a request to marketing@stout.com.
  • For operating and improving Stout’s website and your customer experience. For example, we may collect and analyze data on your use of our website and process it for the purpose of improving our online experience. Please see our Terms of Use and Cookies Policy for additional information.
• For security purposes. For example, we may use your data to protect Stout and its third parties against security breaches and to prevent fraud and violation of Stout’s applicable agreements (where the processing is necessary for our legitimate business interests).

Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.

How data is processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized Stout employees and Third-Party processors to have access to your information. Such employees and Third-Party processors are appropriately designated and trained to process data only according to the instructions we provide them.

Storage of Personal Data

Stout will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements, and in accordance with Stout’s Document Retention Schedule.

Disclosure/Sharing of Personal Data

We only share your personal data with your consent or in accordance with this policy. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this Privacy Policy.

• We share personal data among Stout affiliates and subsidiaries who act for Stout for the purposes set out in this policy.
• Stout may share your information with external third parties, such as vendors, consultants and other service providers who are performing certain services on behalf of Stout. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable service contract, and not for any other purpose. Stout requires these third parties to undertake security measures consistent with the protections specified in this policy.
• Stout may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
• If Stout’s business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.

Cross – Border Transfers of Personal Data

Stout is a global firm. Personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this policy, and in compliance with local regulations.

Data concerning EU data subjects may be transferred to or processed in locations outside of the EU only where one of the following safeguards is in effect:

• Transfers to certain countries which the EU Commission has determined ensures an adequate level of protection;
• Transfers pursuant to standard contractual clauses or contract terms ensuring adequate data protection;
• Where required, Stout entities have entered into European Union Model Clause Agreements which allows for the processing of your personal information and for transfers of your personal information.

Your Rights

You have the following rights concerning your data processed by Stout:

• Access: You have the right to access personal information that Stout holds about you.
• Rectification: You have the right to ask us to rectify information Stout holds about you if it is inaccurate or not complete.
• Erasure: You can request that Stout erase your personal data. We may keep basic data to identify you and retain it solely for preventing further unwanted processing.
• Restrict Processing: You have the right to ask Stout to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.
• Object to processing: Where processing is based on legitimate interests, you have the right to object to Stout processing your data. Stout will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We may keep basic data to identify you and retain it solely for preventing further unwanted processing.
• Portability: Where processing is based on consent or performance of a contract, you have the right to data portability. Stout must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this effecting the usability of your data. This right only applies to personal data that you have provided to Stout as the Data Controller.

Please contact legal@stout.com to request access, rectification, or erasure, or to restrict processing, to object to processing, to request data portability.

Automated Decision Making

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

Stout does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.

Providing Information to Stout

If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website(s).

Third Party Websites or Other Services

We are not responsible for the privacy practices of any non-Stout operated websites, mobile apps or other digital services, including those that may be linked through Stout websites or services, and we encourage you to review the privacy policies or notices published thereon.

Contact Us

Please contact us with questions, concerns, or complaints at:

Stout
150 West Second Street, Suite 400
Royal Oak, MI 48067
legal@stout.com

For data subjects located in the EU: if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular, in the Member State of your habitual residence, place of work or place of the alleged infringement. Contact information for the supervisory authorities may be found here: EU Data Protection Authorities.