





Privacy Policy
This Privacy Policy, which is incorporated into and made a part of the Terms of Use, is entered into and is binding upon you on one side (“You,” or “Your”) and SB Gerard Avenue, LLC, its parents, subsidiaries, affiliates, officers, directors, employees, and agents (collectively, “We,” “Our,” or “SB Gerard”). Please review this Privacy Policy, which governs Your use of InkwellBX.com, and all subpages and subdomains of InkwellBX.com (collectively, the “Site”). By accessing, browsing, or otherwise using in any way the Site, You hereby acknowledge, accept, and agree to be bound by the Privacy Policy.
We will post any modifications or changes to the Privacy Policy on the Site. We reserve the right to modify this Privacy Policy at any time, so We encourage You to review it frequently. If We make a material change to this Privacy Policy, We will post the new Privacy Policy to the Site, which will be effective upon such posting to the Site. Your continued use of the Site signifies Your acceptance of Our Privacy Policy as modified. IF YOU DO NOT AGREE TO ANY PART OF THIS PRIVACY POLICY, PLEASE REFRAIN FROM USING THE SITE.
1. SB Gerard Data Storage Compliance
We may store Your information in the United States and in other locations outside the United States. Any international transfer of Your data will be in compliance with applicable European Union data protection laws.
2. The Information We Collect
Information You Provide – SB Gerard collects a variety of information that You provide directly to us, including any information that may be contained in submissions You upload or post to the Site. The specific types of information collected will depend upon what You choose to provide, and may include Your full name, email address, phone number, home address, mobile phone number, credit card information, gender, birth date, and zip code.
Information We Automatically Collect – When You use the Site, We may collect certain information for the purposes of improving, resolving, or maintaining Our website services, software, troubleshooting bugs, managing the Site, security, and monitoring purposes, tracking and analyzing usage, providing content for referring traffic sources and improving overall performance of the Site. We may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information. We may collect and analyze information about Your computer or mobile device such as Your IP address, a mobile device identifier (e.g., a IDFA on Apple products like the iPhone and iPad or similar advertising identifiers), browser types, browser language, operating system, the state or country from which You accessed the Site, referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time You used the Site, error logs, and other similar information. We monitor customer traffic patterns and Site usage to help us develop the design and layout of the Site, and to improve the content of the Site.
Information from Other Sources – SB Gerard may receive information about You from third parties, such as commerce partners, marketers, social network services, and other parties that We may use to supplement the information that We collect directly from You. If You connect to a third-party network (such as a social network), platform, or service through the Site, You are authorizing us to collect, store, and use in accordance with this Privacy Policy any and all information (such as name, email address and location) that You agreed the network or other third-party platform could provide to SB Gerard based on Your settings on the third-party network or platform. Your agreement takes place when You connect with the third-party network, platform, or service via Our Site.
Anonymous or De-Identified Data – We may collect data that is already in anonymized or de-identified form or We may manually anonymize and/or de-identify information collected by the Site or via other means so that the information does not identify You. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and We may disclose it to others without limitation for any purpose.
3. Cookies and Similar Technologies
Our Site uses cookies. Cookies are small text files that are either stored temporarily on your end device for the duration of a session ("session cookies") or permanently ("permanent cookies"). Session cookies are automatically deleted at the end of your visit to the website. Permanent cookies shall remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser. Third-party cookies may also be stored on your end device when you visit our Site. Such cookies allow you or us to use certain functions of the third-party provider and they cannot be read by us.
Cookies serve a variety of functions. Many of them are necessary for technical reasons, since certain Site functions would not work without them. Under applicable law, We may only store cookies on your device if they are strictly necessary for the operation of this Site. Other cookies are used to analyze user behavior or to display ads. Under applicable law, we may not, and will not, store such cookies on Your device without receipting Your express consent to do so.
4. Online Advertising and Analytics
Online Analytics – We may use third-party web analytics services on Our Site, such as those of Google Analytics. These service providers use the sort of technology described in the “Information We Automatically Collect” section above to help us analyze how users use the Site, including by noting the third-party website from which You arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate Your use of the Site. We also may use third-party web analytics services for certain purposes related to online marketing, as described in the following section.
Online Advertising – We do not serve third-party advertisements to You while using the Site. However, We may work with website analytics and advertising partners, including Google, Doubleclick Campaign Manager, AdRoll, Commission Junction, and Facebook, to deliver SB Gerard advertisements on third-party publisher websites – these partners may set cookies on Your computer's web browser. These cookies allow Our partners to recognize Your computer so that the ad server can show You SB Gerard advertisements elsewhere on the Internet, and so that Our analytics software can measure Your engagement and interactions while using the Site. In this way, ad servers may compile anonymous, de-identified information about where You, or others who are using Your computer, saw Our advertisements, whether or not You interacted with Our advertisements, and actions performed on subsequent visits to the Site. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to You, and it allows SB Gerard to optimize the performance of Our advertising campaigns and the usability of the Site. In other words, We may use analytics data in concert with data about Our online ads that have been shown using website analytics and advertising partners. By doing so, We can understand how anonymous users interacted with the Site after seeing Our ads.
5. Uses of Information
SB Gerard may use the information it collects for various purposes, including but not limited to:
Service Improvement – As discussed throughout this Policy, We will use information to understand how users interact with Our Site and advertisements, provide tailored content and advertising, improve the overall SB Gerard customer and product experience, and perform research and analytics.
Customer Service – Based upon information You provide directly to us, including any information that may be contained in submissions You upload or post to the Site, We may send You a confirmation email confirming Your submission.
Newsletters, Social Media Campaigns, Special Offers and Updates – We may occasionally send You information on services, special promotions, contests, customer satisfaction surveys, and events. Out of respect for Your privacy, We present the option NOT to receive these types of communications.
6. Sharing and Disclosure of Information
SB Gerard does NOT share, sell, rent, or trade information (unless it has been anonymized or de-identified) with third parties for their own promotional purposes, and will only share information as outlined below or with Your consent.
Business Transactions – Information that We collect is considered a business asset. As a result, if We go out of business, enter bankruptcy, or if We are acquired as a result of a transaction such as a merger, acquisition or sale of some or all of Our assets, Your information may be disclosed or transferred to a third-party acquirer in connection with the transaction.
Legal Compliance – We reserve the right to access and disclose Your information when We believe in good faith that such disclosure is necessary to: (a) enforce legal rights and comply with the law; (b) comply with an order from a government entity or other competent authority, (c) prevent or address potential or actual injury or interference with Our rights, property, operations, users or others who may be harmed or may suffer loss or damage; (d) protect Our rights, prevent fraud and/or comply with judicial proceeding, court order, or legal process served on SB Gerard.
Law Enforcement – We may be required to disclose Your information to government or law enforcement officials in response to a lawful request by a public authority or if We have to do so to comply with a legal obligation, including to meet national security or law enforcement requirements. We can also disclose Your information in order to apply, enforce, or defend against any claims made pursuant to, or concerning, this Privacy Policy, Our Terms of Use, to otherwise protect Our rights or the rights of a third-party, to protect the safety of any person, or to prevent any illegal activity (including for the purposes of fraud protection and credit risk reduction).
7. EU Rights to personal information
EU and Swiss individuals have the right, under certain circumstances, to:
- Access their personal information;
- Correct inaccurate personal information;
- Request erasure of their personal information without undue delay;
- Request the restricted processing of their personal information;
- To receive the personal information that they have provided us with, in a structured, commonly used and machine-readable format and You have the right to transmit that information to another controller without hindrance or ask us to do so; and
- To object to the processing of their personal information.
Such users may request access to, and removal of, their personal information by contacting us directly via email at Privacy@StellarManagement.com EU and Swiss users also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of their habitual residence, place of work or place of the alleged infringement if they consider that Our processing of their personal information infringes the applicable data protection laws. Please contact us at Privacy@StellarManagement.com and We will provide You with detailed information regarding the contact details of the respective competent supervisory authority.
8. Third Party Website Links and Features
The Site may contain links to or features from other websites. This Privacy Policy covers the privacy practices by SB Gerard and does not cover the privacy practices of third-party websites or features. SB Gerard is not responsible for the privacy policies and/or practices of third parties. When linking to another site or using a third-party service, You should read the privacy policy on that site or service. To the extent certain third-party website features are available on the Site, the terms of use and privacy policy of that third-party site and/or features apply.
9. Children’s Privacy
The Site is intended for general audiences and not for children under the age of 13. We do not knowingly collect personal information from children under the age of 13 and if We become aware of such collection, We will take reasonable steps to delete any such information as soon as practicable.
10. International Users
The Site is directed at and intended for users exclusively in the United States and as a result, the information We collect may be stored in the United States. By using the Site, You acknowledge and agree that Your information may be transferred to, used, processed, or held by SB Gerard in the United States and in other countries, including countries outside of Your country of residence and used for the purposes set out in this Privacy Policy.
11. Changes in Our Privacy Policy
From time to time, Our information practices may change. If We decide to change Our Privacy Policy, We will post those changes to this Privacy Policy on the Site or other places We deem appropriate so that You are aware of what information We collect, how We use it, and under what circumstances, if any, We disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If We make a material change to this Privacy Policy, We will post the new Privacy Policy to the Site, which will be effective upon such posting to the Site.
12. How We Protect Your Information
The security of Your information is important to us. We have implemented reasonable administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of Your information based on its sensitivity. Despite Our best efforts, however, no security measures are completely impenetrable.
13. SB Gerard Contact Info
If You wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details:
Privacy@StellarManagement.com

