Stable Rock Solutions LLC

Privacy Policy Statement

Last Updated: August 28, 2025

At Stable Rock, accessible from stablerock.com, one of our main priorities is the privacy of our visitors.

This Privacy Policy Statement (“Privacy Policy”) describes the types of Personal Information that we collected, along with how we record and use your Personal Information.

This Privacy Policy applies only to our online activities and is not applicable to any information collected offline or via channels other than this website.

By accessing, visiting, or using the Website, you acknowledge your understanding of this Privacy Policy and consent to its terms. If you do not agree with the contents of this Privacy Policy, you should not access, visit, and/or use the Website.

We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

II. Definitions of Terms Used in this Policy

“CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.

“Device” means any computer, tablet, mobile phone, or any other device capable of accessing the Website.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, Device, or household. Anonymous, de-identified, or aggregate information is not Personal Information.

“Sensitive Personal Information” means personal information that reveals (a) consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

“Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Information for their own purposes.

“We,” “Us,” “Our,” and “Stable Rock,” whether capitalized or not, means Stable Rock Services LLC and its affiliates.

“Website,” whether capitalized or not, means this website.

“You” or “Your,” whether capitalized or not, means all those who access, visit, and/or use the Website.

III. Categories of Your Personal Information that We May Acquire

We may collect, obtain, or otherwise acquire the following types of Personal Information about you, and we may make and retain inferences drawn from such information:

1. Identifiers, such as your name, date of birth, signature, postal address, ZIP code, email address, telephone number, unique online identifier, IP address, User ID, and Device ID.
2. Certain characteristics protected by applicable law, such as gender, marital status, nationality, and country of origin.
3. Commercial information, such as purchase history.
4. Internet or other electronic network activity information, such as website or app activity data, call logs, text messages, and emails.
5. Geolocation data, such as the physical location of your Device.
6. Professional or employment-related information, such as occupation, employment history and record, and resume.
7. Government issued identification numbers (e.g., social security number, driver’s license number, passport number, military ID number, or state identification card number).

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

IV. How We Acquire Your Personal Information

Personal Information You Provide. We may receive Personal Information directly provided by you. For example, if you contact us through the Website, you may provide your contact information.

Personal Information Automatically Collected. We may automatically collect certain information, some of which may be deemed Personal Information. The information collected may include information about your Device and geographic location of you and/or your Device, as well as date/time stamp, IP address, webpages visited and actions taken on webpages, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.

Personal Information Acquired from Third Parties. We may acquire your Personal Information from third parties. For example, we may purchase or otherwise acquire Personal Information from third-party consumer data suppliers/resellers, data aggregators, advertising networks, data analytics providers, internet service providers, operating systems and platforms, data brokers, business contact databases, government entities, and our affiliates and other related entities.

V. How We Use Your Personal Information

We use the information we collect in various ways, including to:

1. Provide, operate and maintain our Website.
2. Improve, personalize, and expand our Website.
3. Understand and analyze how you use our Website.
4. Develop new products, services, features, and functionality.
5. Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes.
6. Send you emails.
7. Send you non-marketing SMS/text messages. If you provide your mobile phone number, we may use it to send you non-marketing text messages related to your account or services (e.g., authentication codes, appointment reminders, or support communications). Message frequency may vary. Standard message and data rates may apply. You may opt out at any time by replying STOP, or request assistance by replying HELP.
8. Find and prevent Fraud.
   

Stable Rock does not sell Personal Information for monetary consideration. We may, however, share or otherwise disclose your Personal Information in the ways listed below. Except for advertising partners (who may use the data for their own marketing subject to your opt-out choices), each recipient may handle the information only to perform services for us or as otherwise required by law.

• Service Providers. We may share your Personal Information with vendors that operate our website, client portal, and bookkeeping services—such as cloud-hosting providers, payment processors, IT-support firms, and analytics or marketing-platform providers.
• Third-Party Integrations. Our Website may use third-party services and integrations (such as analytics tools, customer support platforms, advertising networks, embedded media, and payment portals). These third parties may collect information directly from your browser or device in accordance with their own privacy policies.
• Advertising Networks & Social-Media Platforms. We may share your Personal Information (e.g., cookie and device IDs) with Google Ads, Meta, LinkedIn, and similar platforms to deliver targeted or cross-context behavioral advertising. You can opt out at any time via the “Cookie Settings” control.
• Affiliates and Subsidiaries. We may share your Personal Information within the Stable Rock group for internal administrative purposes.
• Integration and Referral Partners. We may share your Personal Information with partners with whom we jointly market or deliver products or services that you request.
• Professional Advisors, Regulators, and Law-Enforcement Authorities. We may share your Personal Information with lawyers, accountants, consultants, government agencies, or courts when required to comply with legal obligations, resolve disputes, or defend our rights and property.
• Health, Safety, and Legal Requests. We may share your Personal Information to cooperate with official investigations, respond to subpoenas, search warrants, or other legal process, and to protect the health or safety of individuals.
• Successor Entities. We may share your Personal Information with, or transfer it to, another company in connection with, or during negotiations of, a merger, acquisition, financing, or sale of all or part of our business.
• Marketing Communications. We may use your Personal Information to communicate with you about services we offer.

In every case, your Personal Information may be used by Stable Rock and by the applicable third parties only for the purposes described above or as otherwise permitted by their own privacy policies. Stable Rock’s Privacy Policy does not govern the practices of those third parties; please review their privacy notices for additional details and opt-out options.

VII. Log Files, Cookies and Web Beacons

Stable Rock follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this as part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of such information is to analyze trends, administer the website, track users' movement on the website, and gather demographic information.

Like any other website, Stable Rock uses "cookies." These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites

Advertising partners of Stable Rock utilize third-party ad servers or ad networks which use technologies like cookies, JavaScript, or Web Beacons, in their respective advertisements and links that appear on Stable Rock, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that Stable Rock has no access to or control over these cookies that are used by third-party advertisers.

Stable Rock uses four categories of cookies—Strictly Necessary, Functionality, Performance/Analytics, and Targeting/Marketing—and may deploy web beacons or pixels (for example, Google Analytics, HubSpot, LinkedIn Insight Tag, and Meta Pixel) to support these purposes. Most identifiers expire within 24 months unless you clear them sooner. You can adjust or withdraw consent at any time by clicking “Cookie Settings” in the footer; Stable Rock also honors browser signals sent via the Global Privacy Control (GPC).

VIII. Protection of Your Personal Information

Security Measures. We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of, Personal Information.

No Liability for Breach. Because no security system is impenetrable, we cannot guarantee the security of your Personal Information. By using the Website, you agree to assume all risk in connection with your Personal Information. We are not responsible for any loss of such Personal Information or the consequences thereof.

Breach Notification. If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.

Retention. We will retain your Personal Information for as long as it is reasonably useful for commercial purposes. We will retain and use your Personal Information as necessary to comply with our legal obligations or data retention policies, resolve disputes and enforce our agreements.

IX. Notice to California Customers – Your Privacy Rights

Rights of California Residents. The CCPA grants residents of California certain rights with respect to their Personal Information.

California residents have the following rights under the CCPA:

1. The right to know the categories of Personal Information we have collected about you;
2. The right to know the categories of sources for the personal information we collected about you;
3. The right to know our business or commercial purpose for collecting your Personal Information;
4. The right to know the categories of third parties with whom we share or disclose your Personal Information;
5. The right to know the ways in which we collect, use, share, disclose, and otherwise process your Personal Information;
6. The right to know the specific pieces of your Personal Information that we hold;
7. The right to request the deletion of your Personal Information, subject to several exceptions;
8. The right to opt out of the sale or sharing of your Personal Information;
9. The right to correct inaccurate Personal Information that we hold;
10. The right to request that we limit the use and disclosure of sensitive Personal Information collected about you; and
11. The right not to be unlawfully discriminated against for exercising these rights.

We may take reasonable steps to verify your identity before fulfilling your request to know or delete your Personal Information that we hold. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.

Exercising Your Rights Under the CCPA. California residents, as well as authorized agents seeking to submit requests on behalf of California residents and parents or guardians seeking to submit requests on behalf of their minors who are residents of California, may exercise the rights described below by contacting us at info@stablerock.com or by calling us at 212-503-2852.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct any of our affiliates to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us to:

1. Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you opt out of the sale of your Personal Information, we may still share your Personal Information with third parties if those transfers are not sales, such as with any affiliates.

Consumers’ Right to Know What Personal Information is Sold or Shared and to Whom. The CCPA gives California residents the right to ask us to disclose (1) the categories of Personal Information that we collect about our consumers; (2) the categories of Personal Information that the business sold or shared about the consumer and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared; and (3) the categories of personal information that the business disclosed about the consumer for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

If you are a California resident and would like to request this notice, please submit a written request to the email or regular mail address provided in “Section XII: Privacy Policy Coordinator” below.

Response Timing and Procedures. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Categories of Personal Information We Disclose. We may disclose your Personal Information to a third party for a business purpose. In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:

Categories of Personal Information We Sell or “Share”.

During the past 12 months, Stable Rock has not sold Personal Information for monetary consideration. For the limited purpose of delivering and measuring targeted online advertising, however, we have “shared” (as that term is defined under the California Privacy Rights Act) the following categories of Personal Information with third-party advertising networks and social-media platforms such as Google Ads, Meta (Facebook), and LinkedIn:

1. Identifiers: for example, IP address, device ID, and unique cookie or pixel identifiers that recognize your browser or device; and
2. Commercial or Internet Activity Information: such as the pages you view on our site, clicks on marketing emails, and interactions with our online ads.

Stable Rock does not sell Sensitive Personal Information and does not knowingly sell or share Personal Information about individuals under 16 years of age. We may disclose Sensitive Personal Information to trusted service providers and contractors that process data on our behalf under written agreements limiting its use to the services requested. You may opt out of the sharing described above at any time by selecting “Do Not Sell or Share My Personal Information” in the footer or by adjusting your preferences in the “Cookie Settings” panel; we also honor browser signals sent via the Global Privacy Control (GPC).

Do Not Track. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third-party ad networks, social networks, and analytic companies. We do not currently take actions to respond to DNT signals, because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.

X. Additional Privacy Considerations

Children’s Privacy

Our Website is not directed to, and we do not intend to or knowingly collect or solicit Personal Information online from, children under the age of 16. If a child under 16 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us through the contact information provided below to request that we remove the information from our systems. If you are under the age of 16, do not provide us with any Personal Information.

Privacy Rights for Other Jurisdictions

Residents of Virginia, Colorado, Connecticut, Utah, the European Union/EEA, the United Kingdom, and other jurisdictions may have additional rights regarding their personal information, including rights to access, correct, delete, or restrict processing of their personal data, as well as the right to data portability and to object to certain processing activities. You may exercise these rights by contacting us as set out below.

International Data Transfers

Where we transfer personal information outside of the jurisdiction in which it was collected, including transfers to the United States, we rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission or other legally recognized transfer mechanisms.

Payment Processing

Stable Rock uses third‑party payment processors (currently Stripe and QuickBooks) that are independently responsible for the security of your payment card data and comply with the PCI‑DSS standard. Stable Rock does not store full payment card numbers.

Data Security and Retention

We use administrative, technical, and physical safeguards—including encryption at rest and in transit, role‑based access controls, and annual penetration testing—to protect personal information. We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. When retention is no longer required, we will delete or anonymize data in accordance with our internal schedule.

Complaints

If you believe we have not handled your privacy concerns to your satisfaction, you have the right to lodge a complaint with your local supervisory authority or with the U.S. Federal Trade Commission.

XI. Privacy Policy Coordinator

If you have any concerns or questions about any aspect of this Privacy Policy, please feel free to contact our Privacy Policy Coordinator by email or as follows:

Privacy Policy Coordinator
Stable Rock Solutions LLC
2 West 45th Street
Suite 1208
New York, NY 10036

info@stablerock.com

Please include your name and contact information in your request.

Only inquiries about this Privacy Policy or your Personal Information should be sent to the Privacy Policy Coordinator. No other communications will be accepted or responded to.

Changes to This Privacy Policy
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We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.