S&B Privacy Policy

This Privacy Policy explains what S&B Administrative Services, Ltd. (“S&B”) does with Personal Information (defined below) that you provide to S&B in and through this website as a visitor (“Visitor”), or if you are a potential business contact, during the course of your business dealings with us (“Potential Customer”).  Collectively, Visitors and Potential Customers shall be referred to as “Website Users”.

S&B and its affiliates are primarily an Engineering, Procurement, and Construction (“EPC”) company, which largely utilizes a project delivery model where a single contractor manages the entire lifecycle of a project from design to completion (“Services”).  This model is commonly used in the private sector for large-scale and complex infrastructure projects.  We also go beyond general contracting by offering innovative strategies in engineering, construction management, and long-term operations—supporting engineering and construction throughout a facility’s lifecycle.

This Privacy Policy applies to Personal Information S&B may collect through our websites, apps, or other online media under its operation and control (collectively, the “Sites”). However, this Privacy Policy does not apply to Personal Information we collect about S&B's employees or about individuals representing customers who are only business contacts for those customers (i.e., no independent relationship with S&B except as the representative of a customer) (“Customer”); in most jurisdictions, that information does not fall within the definition of “Personal Information.”  Despite that, S&B nevertheless protects information from employees and Customers as confidential.

S&B values your business and the trust you place in us. To help you better understand how Website Users' information is used and protected at S&B, this Privacy Policy outlines (a) definitions of “Personal Information”, (b) methods and sources of collecting Personal Information, (c) how we use your Personal Information, (d) how we protect your Personal Information from disclosure, (e) your rights regarding your Personal Information, and (f) measures and efforts we take to safeguard Personal Information.  This information is based on the current state laws and regulations governing the collection and use of Personal Information.  Because those various state laws are not fully consistent with one another, S&B has developed this Privacy Policy that is designed to comply to the maximum extent possible with all of those laws and regulations.

S&B reserves the right to revise this Privacy Policy at any time without prior notice. For this reason, please check regularly for the most recent version of our Privacy Policy and its implications for you.

Definitions

In our Privacy Policy:

Categories of Personal Information we collect:

Sources of Personal Information

Personal Information you Provide
S&B collects Personal Information about individuals when provided by such individuals for purposes disclosed or otherwise known to them when they provide their information or for the wider purposes set out below. This includes, for example, providing a business card in a meeting, registering to attend a meeting, sending us an email which includes Personal Information about you, providing basic details for building security purposes when you enter S&B premises, or allowing us to photograph, film or otherwise record you when you attend an event that we host/sponsor or enter a project area under S&B control.

Unless we explain otherwise at the time, providing Personal Information that we request is optional and disclosures are made voluntarily.

Automatic Collection of your Personal Information
We collect certain Personal Information by automated means when you visit our premises or Sites. In particular:

S&B uses this Personal Information, in aggregated form, to perform statistical analyses of the collective characteristics and behavior of our Website Users and to measure overall user demographics and interests regarding specific areas of the Sites.

Collection of your Personal Information from Third Party Sources
If you are involved in a business relationship with us as a Potential Customer, we may also obtain some limited information about you indirectly, for example when your colleagues give us your contact details and information about your role, or from publicly available sources such as the Internet and/or subscription-based services.

Data Minimization

As required by some state consumer privacy laws and as a matter of good practice, we collect only the Personal Information that is reasonably necessary and proportionate to provide the Services described above. We do not collect additional categories of Personal Information, including any “Sensitive Information” such biometrics or geolocation information (e.g. GPS), or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you an updated notice.

Use of your Personal Information

We use your Personal Information for the following purposes:

S&B does not trade, sell or rent Personal Information but may collect or provide aggregate statistics about its Sites and Website Users to other parties who do not provide services directly to S&B.

Except in rare circumstances where S&B is required by law to disclose or otherwise process your Personal Information, S&B will only process your Personal Information as necessary for the purposes explained to you when the information is collected or otherwise set out in this Privacy Policy. S&B will not collect your Personal Information unless it has concluded that it has a legitimate interest in pursuing the relevant purpose. We will ask for your consent to allow us to process your Personal Information – for example, we will generally seek your consent if we wish to use images of you in published materials relating to an event that you attended.

Disclosures of Personal Information

S&B and its affiliates may share Personal Information about you between the related companies, and may disclose your Personal Information to technology and other service providers, including professional advisors, who hold and process the information on S&B’s behalf.

S&B may also disclose your Personal Information if it has a good faith belief that disclosure is necessary for the legal and compliance purposes set out above. For these purposes, we may, for example, disclose information about you to courts and litigation counterparties, insurers, law enforcement and other competent governmental authorities.

As we continue to develop our business, we might sell or buy assets. In such transactions, Personal Information as protected in our systems is generally one of the transferred business assets. Also, if either S&B itself or substantially all of S&B’s assets were acquired, Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer Personal Information to a third-party purchaser in these circumstances, under protective terms.

How We Protect Your Personal Information from Disclosure

S&B DOES NOT SELL YOUR PERSONAL INFORMATION. S&B DOES NOT SHARE YOUR PERSONAL INFORMATION WITH ANY THIRD PARTY FOR ANY COMMERCIAL PURPOSES.

No External Access to Personal Information
Your Personal Information will only be used by S&B or its contracted service providers to fulfill its obligations to you in accordance with its relationship with you.  No other third party has access to your Personal Information held in our systems. All reports, data feeds, and analytics that are provided to contracted service providers contain only encrypted Personal Information data.

Contracted Service Providers
S&B engages certain contracted service providers to assist in delivering Services. These service providers process data on S&B's behalf and under S&B's direction. In those situations, S&B requires its service providers to sign an agreement that prohibits them from using your Personal Information outside of the contracted Services. Our service providers include providers of cloud hosting and system performance monitoring services – none of whom are legally allowed to use your Personal Information outside of the work they perform for S&B.

Required Disclosures
S&B may disclose Personal Information as required by law, as required to protect the rights or safety of S&B or our Customers, or in response to a specific law enforcement request.

Aggregated Data
S&B may share anonymous and aggregated information about all our users with third parties for program analytics and industry trend reporting. It is not possible for those third parties to determine who you are from such information.

Your Rights

Universal Rights
Given the emerging privacy laws in the United States, S&B has adopted a Privacy Policy that, regardless of where you reside, your rights in relation to your Personal Information are to:

  1. Be informed about how your Personal Information is collected, used, and protected by S&B;
  2. Access your Personal Information held by S&B;
  3. Correct inaccuracies in your Personal Information;
  4. Delete your Personal Information, subject to certain exceptions described below;
  5. Restrict how we use your Personal Information; and
  6. Withdraw from the collection of your Personal Information at any time.

Service Participation and Withdrawal
Participation in any S&B Service is entirely voluntary. Subject to any applicable legal contract, you may request the withdrawal of your Personal Information at any time. 

Except as otherwise provided in any Customer contract between S&B and Customer, withdrawal from Services will terminate all Personal Information data processing. 

Right to Delete
The right to have us delete your Personal Information carries an important caveat. If you ask us to delete your Personal Information, you will not be able to continue using our Services. We will respond within a reasonable time to any request from you to indicate your options if you still want to delete your Personal Information.

We may retain certain anonymized and aggregated information as required or permitted by applicable law, including but not limited to: providing Services, detecting and resolving security incidents, complying with legal obligations (including as provided in any contract between S&B and Customer), and exercising or defending legal claims.

Right to Data Portability
You may have the right to request to have your Personal Information transferred to other businesses; however, because our use of your Personal Information is limited to fulfilling Services, it is usually not technically feasible for us to honor such a request because we are not able to exchange that information with other businesses with which we have no direct interface or where we have no existing business reason to exchange data. We will respond within a reasonable time to any request from you to export your Personal Information.

Right to Appeal
If we decline to take action on a request you have made regarding your Personal Information, we will inform you of our reasons for doing so and provide instructions for how to appeal the decision. You may appeal by contacting us at the information provided in the Contact Us section below. We will respond to your appeal within the timeframes required by applicable law. If your appeal is denied, we will provide you with information on how to contact your applicable regulatory authority to submit a complaint.

Authorized Agents
In some jurisdictions, you may designate an authorized agent to make a request on your behalf. To do so, you must provide the authorized agent with written permission to act on your behalf, and we may require you to verify your own identity directly with us before we fulfill the request.

Non-Discrimination
S&B will not discriminate against you for exercising any of the rights described in this Privacy Policy.

Opt out
S&B recognizes and honors Global Privacy Control ("GPC") signals and other universal opt-out preference signals transmitted by your browser or device, to the extent required by applicable law. If we detect a GPC signal from your browser or device, we will treat it as a valid request to opt out of the sharing of Personal Information associated with that browser or device, as applicable under the laws of your state of residence.

Because S&B does not sell Personal Information or share Personal Information with any third party for any commercial purposes, a GPC signal will not materially change your experience with the Sites. However, we honor these signals as a matter of principle, good practice, and legal compliance.

Additionally, if you no longer wish to receive our marketing communications, you may opt out of receiving them by following the instructions included in the specific communication.

Cookies and Similar Technologies
Generally, we use cookies, web beacons, pixels and tags to: optimize and improve our Sites; identify your device; distinguish you from other visitors; record your IP address to understand your use of our Sites; provide user authentication; monitor and maintain information about your use of the Sites; identify the name of the website from which you linked to our Sites; and, to conduct fraud prevention and website management.

A cookie is a small text file that is stored on a computer or device when you use the Sites. If you reject our cookies and/or similar tracking technologies, you may still use the Services, but your use may be limited or burdensome. We use both session ID cookies and persistent cookies. A “session ID” cookie expires when you end your session (i.e. close your browser). We use session cookies to make it easier for you to navigate the Sites.  A “persistent” cookie remains on your hard drive which means that when you end your session and return to the same Sites later, the cookie information is still available. We may set a persistent cookie to store any password so you do not have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance experiences on the Sites.

We use the following types of cookies:

Security of Your Personal Data

S&B uses physical, technical, organizational, and administrative safeguards in providing our Services designed to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of Personal Information we collect and use. Our security controls are designed to maintain data confidentiality, integrity, and an appropriate level of availability. However, we cannot ensure or guarantee the security of any information you transmit to us.  Messages that you send to S&B by email may not be secure, and use of email is not recommended for sending S&B confidential or sensitive information.

S&B maintains a comprehensive information security program that includes physical, electronic, and procedural safeguards designed to protect Personal Information from unauthorized access, use, modification, or disclosure. Our security program includes:

S&B’s service providers and affiliates that receive Personal Information are required to preserve the confidentiality of that information under the terms of our applicable contractual agreements.

Data Breach Notification

S&B has adopted a Cybersecurity Incident Response Plan to ensure that it has a mechanism to monitor and detect any security incident and then determine if there has been a data breach that may have involved unauthorized access to Personal Information – and finally to remediate such breaches.

In the event of a confirmed security breach that compromises your Personal Information, S&B will notify affected individuals and applicable regulatory authorities in accordance with the notification requirements of all applicable federal and state laws. In accordance with applicable law, notification will include a description of the incident, the categories of Personal Information affected, and the steps we are taking in response, as well as recommendations for steps you can take to protect yourself.

Retention of your Personal Information

S&B retains your Personal Information in accordance with our business relationship.   We also retain Personal Information in accordance with S&B's records management policies (unless we delete the information earlier at your request). You may contact S&B at privacy@sbec.com  for more information on record retention periods. 

Storage of your Personal Information

S&B uses third-party cloud storage providers to store S&B data, such as company emails, that may include your Personal Information. In such circumstances, S&B has an agreement with those providers that they cannot use your Personal Information for any purpose outside of the contract with S&B.  As such, these agents will not have access to your Personal Information other than to facilitate S&B’s storage and retrieval of that data.

Links to Other Websites

This Privacy Notice applies only to the Sites and not to any other websites that may be linked together. Since we are unable to control the Internet or the websites of other companies, we cannot be responsible for the standards of Sites other than our own. This Privacy Policy has no relationship or governance of any non-S&B website. You can learn about the information handling practices of non-S&B websites by reading the privacy policy linked to those sites.  You are responsible for reviewing and understanding the privacy policies of any third parties that you link to through our Sites.

Minors

S&B has no need or intention to collect customer information about anyone under the age of 18.  The Sites and our Services are all directed to people who are at least 18 years old or older. If you are under the age of 18, you are not authorized to use the Sites.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make a change to this Privacy Policy, we will inform you by posting an updated policy on S&B’s Sites. Those changes will go into effect on the effective date posted in the revised policy. The new Privacy Policy will replace any prior policies that are inconsistent. Please check periodically for changes to this Privacy Policy, and especially before you provide any Personal Information to us.

Contact Us

If you have any questions or comments regarding this Privacy Policy or our information collection practices, please contact us by sending an email to privacy@sbec.com or by writing to:

S&B 
Attention:  Legal Department - Privacy
15150 Memorial Drive
Houston, Texas 77079

Acknowledgement

I hereby make the following statement:

I have read the above information presented by S&B about its Privacy Policy, including the Cookies and Similar Technologies section. I hereby recognize and acknowledge that S&B has provided me with notice and information about its privacy policies and practices as stated herein, including collecting and using my Personal Information. In addition, in some situations where I may be able to give affirmative consent to S&B to collect and use my Personal Information, I hereby give such consent. I am aware that I have the right to seek to withdraw my consent at any time with effect for the future, by emailing or contacting S&B in writing at Contact Us details above.