Privacy Policy

Sinclair Privacy Notice

Last Updated: March 21, 2025

Our Privacy Notice Has Recently Changed.

Your privacy is important to Sinclair (“our,” “us,” or “we”). This Privacy Notice (the “Notice”) explains the types of information we may collect from you or that you may provide when you visit the website https://www.sinclair-intl.com/ (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Notice does not apply to information collected through any other means, including on any other website operated by a third party.

Please read this Notice carefully. If any term in this Notice is unacceptable to you, please do not use our Website or provide us with any personal information.
In this Notice, when we talk about “Personal Information,” we mean any information that is related to an identified or identifiable natural person.
This Notice does not apply to any products, services, websites, mobile applications, or content (including advertising) offered by third parties or that may be linked to or from the Website. Data collected by these third parties is covered by their own privacy notices.

1. Your Information We Collect

Depending on your relationship with us, we may collect the following categories of Personal Information from you:

Personal Details: Name, email address, mailing address, telephone number, company name, job title, and other professional and employment information;
Device and other automatic information: IP address, browsing history, search history, and information regarding your interactions with a website, application, or advertisement. For more information, see “Information We Collect Automatically About You” below;
Employee and Job Applicant Information: If you are an employee or have applied for a job or other position with us, we may also collect employment information such as your name, resume/CV, educational background, language and other skills, work experiences, and job references. The collection, use, and disclosure of your Personal Information is governed by our Employee and Job Applicant Privacy Notices.

2. How We Collect Your Information

Information We Collect Directly From You

We may collect Personal Information that you provide to us when you use our Website or interact with us. For example, we may collect information when you browse through the Website, make an information request, or when you otherwise interact with us and provide your information via our Website.

Information We Automatically Collect About You

As with many websites, when you interact with our Website, we may use automatic data collection technologies to collect and log certain information about your equipment, browsing actions, and patterns, including details of your visits to our Website (e.g., traffic data, logs, other communication data, and resources that you access and use on our Website), information about your computer, mobile device, and internet connection (including your IP address, operating system, and browser type), and location data, which we collect to ensure you reside in a jurisdiction in which you are eligible for using our Website, to comply with relevant laws, and for fraud prevention purposes.

Cookies

The technologies we use for automatic data collection include cookies (i.e., browser cookies), flash cookies, and web beacons. We may store cookies (e.g., locally stored objects) on your device when you use our Website. These technologies help us speed up your future activities and improve your experience by remembering the information that you have already provided to us. Third parties operating on our behalf may also use these technologies to provide us with anonymous data and information regarding the use of our Website. You may block or delete these technologies from your device. However, by disabling such technologies, you may not have access to the entire set of features of our Website. For more information about cookies, including links to web browser instructions for disabling and managing such technologies, visit https://optout.networkadvertising.org/.

We use Google Analytics to collect information on your use of our Website. Google Analytics collects information such as how often users visit our Website, what pages they visit, and other websites visited prior to or after coming to this Website. The data collected through these tools is not tied to other Personal Information that we collect about you. To know more about data collected by Google Analytics, visit https://www.google.com/policies/privacy/.

You may prevent the use of Google Analytics by disabling cookies as described above. You may also prevent Google Analytics from recording the data generated by the cookie and pertaining to your use of our Website (including your IP address), or processing this data, by downloading and installing the following browser plug-in available through Google at the following link: https://tools.google.com/dlpage/gaoptout.

Information We Collect From Other Sources.

We may collect Personal Information about you from our affiliates and our partners and their service providers and contractors. For example, this may include your current job position, business address, company name, and position title provided by your employer. We also may obtain information you have made publicly available, including from websites and online services you use, consumer research platforms, and/or business contact databases.

3. How We Use Your Information

We may collect Personal Information for the following purposes:

Provide our Website and its contents to you;
Provide or improve the services requested by you, including in the context of your business relationship with us, and perform our contractual obligations;
Fulfill or meet the reason you provided the information (e.g., to respond to your email or request for information);
Communicate with you about our Website or to provide you with information or marketing materials that may be of interest to you;
Send you transactional or relationship messages, such as receipts, account notifications, customer service responses, and other administrative messages;
Monitor and analyze trends, usage, and activities in connection with the Website;
Comply with the law, and protect or defend our interests or the interests of our customers or users of our Website if permitted by law or required to do so by law, court order, or government regulations or where we believe such action is necessary;
Help maintain the safety, security, and integrity of our Website, products and services, databases, other technology assets, and business;
System administration and to monitor the use of our Website;
Any other purpose disclosed by us when you provide the information or with your consent; and
Disclose to third parties for the performance of services provided to us, including third-party providers of services related to the operation and management of our Website, or in connection with the administration and support of the activities noted above.

4. With Whom We Disclose Your Information

We may disclose information about you as follows and as otherwise described in this Notice or at the time of collection:

With companies and vendors that perform services for us, including email service providers, fraud prevention vendors, analytics providers, and other service providers;
To accountants, auditors, lawyers, and other outside professional advisors to the Company, subject to appropriate contractual obligations of confidentiality;
Where required by law, court order, or subpoena if we believe disclosure is in accordance with, or required by, applicable law or legal process or where necessary to prevent, detect, or prosecute criminal offenses or to protect the rights, property, and safety of the Company or others;
In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
Between and among the Company and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
With your consent or at your direction.

We may also process and disclose information to third parties if the information has been de-identified or aggregated in a way so it cannot be used to identify you.

5. How We Protect Your Information

We use reasonable security measures to protect your Personal Information. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

6. Data Retention

We retain your Personal Information so long as necessary for the purposes for which it was collected or otherwise processed. When determining the retention period, we take into account criteria, such as the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and the applicable legal requirements. [Details of retention periods for different aspects of your Personal Information are available in our retention policy which you can request by contacting us in accordance with Section 10 “How to Contact Us.”]

7. Children

The Website is not directed towards children. We do not knowingly collect Personal Information from children under the age of 13 (or 16 where applicable by law) through the Website. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Notice by instructing their children to never provide Personal Information through the Website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us using the methods described in Section 10 “How to Contact Us,” and we will endeavor to delete that information from our databases.

8. Links

The Website may contain content, services, advertising, and other materials that link to external websites. We do not endorse and are not responsible for the content of any such external website. Please refer to the terms of use and privacy notices of the external website for more information.

9. Changes to This Notice

This Notice is effective as of the date stated at the top of this Notice. We may change this Notice from time to time. Your access of the Website after such change will be deemed acceptance of the new Notice.

10. How to Contact Us

If you have any questions or concerns about our privacy practices or about exercising your rights, you may send an email to sinclairinfo@sinclair-intl.com or call us at +44 1603 726400. You may also write to us at: Sinclair International Ltd, Jarrold Way, Bowthorpe Employment Area, Norwich, NR5 9JD.

11. Other Choices

Promotional Communications. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.

Communications to Mobile Devices. With your consent, we send promotional and other push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

12. Additional Information for Residents of California

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (Civil Code Section 1798.100, et seq.) (“California Law”), provides eligible California residents with specific rights with respect to our collection, retention, disclosing, selling, sharing, and use of Personal Information. This section on “Additional Information for Residents of California” supplements this Notice and applies solely to eligible residents of the State of California. Any terms used but not defined in this section have the same meaning as defined in California Law.

Collection of Personal Information

In the preceding twelve (12) months, we have collected categories of Personal Information as discussed in Section 1 “Your Information We Collect” from the sources of Personal Information as discussed in Section 2 “How We Collect Your Information.” The business or commercial purpose for collecting that information is disclosed in Section 3 “How We Use Your Information.”

Disclosure of Personal Information

In the preceding twelve (12) months, we may have disclosed your Personal Information for a business or commercial purpose described in Section 3 “How We Use Your Information” to the categories of third parties described in Section 4 “With Whom We Disclose Your Information.”

Sales and Shares of Personal Information

We do not sell your Personal Information for monetary profit. However, we engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. In the last 12 months, we have sold or shared the following Personal Information:

Category	Business or Commercial Purpose	Categories of Third Parties to Whom Personal Information was Disclosed That May be Considered a “Sale”/“Sharing” Under California Law
Identifiers	To be able to deliver Sinclair products and services	Approved Sinclair Agents
Internet or other similar network activity	To provide you with personal advertising and content	Advertisers and advertising networks

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

California Privacy Rights

California Law provides consumers with specific rights regarding their Personal Information. The following section describes your California Law rights and explains how to exercise those rights. Your California Law rights include the:

Right to Know or Access: Request that we disclose to you your Personal Information that we collected, used, disclosed, shared, and sold.

Right to Delete: 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 (see “Identity Verification”), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Right to Correct Inaccurate Personal Information: Request that we correct any of your Personal Information that we maintain about you that is inaccurate.

Right to Opt Out of Sales or Sharing of Personal Information: We do not sell your Personal Information for monetary profit. However, we may engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. If we sell your Personal Information to or share such information with third parties, you may have the right to opt out of the sale or sharing of such information. To exercise the right to opt out, you (or your authorized representative) may submit a request to us by emailing sinclairinfo@sinclair-intl.com link on the homepage.

If you have an opt-out preference signal enabled (e.g., the Global Privacy Control), you will automatically be opted out of the sale or sharing of your information, but we may ask you to confirm your preference if you have previously consented to the sale or sharing of your Personal Information. To download and use a browser supporting the opt-out preference signal, please visit https://globalprivacycontrol.org/orgs. If you choose to use the opt-out preference signal, you will need to enable it for each supported browser or browser extension you use.

Right to Non-Discrimination: We will not discriminate against you for choosing to exercise any of your rights. If you exercise certain rights, understand that you may be unable to use or access certain features of the Website.

Exercising Your Rights

To exercise your California privacy rights, please submit a request by contacting us via the methods in Section 10 “How to Contact Us.”

Identify Verification

We may require you to prove your identity to exercise certain rights. Depending on your request, we will ask for information such as your name, your telephone number, email address, and/or date of last communication with us. We may also ask you to provide a signed declaration confirming your identity. We will only use Personal Information provided in your consumer request to verify your identity or authority to make the request.

Only you, your parent, guardian (if you are under 13 years or age), conservator, a person to whom you have given power of attorney, or an authorized agent may make a verifiable consumer request related to your Personal Information. You may, however, make a verifiable consumer request on behalf of your minor child if necessary. Your verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative. We cannot respond to your request if we cannot verify your identity or authority to make the request. You may only make a verifiable consumer request for your right to access twice within a 12-month period.

Data Retention

We retain your Personal Information so long as necessary for the purposes for which it was collected or otherwise processed. When determining the retention period, we take into account criteria, such as the type of services requested by or provided to you, the nature and length of our relationship with you, use of our Website, and the impact on the Website functionality if we delete your Personal Information.

13. Additional Information for EEA Users

If you are in a country in the European Economic Area (EEA) or in the United Kingdom, you are entitled to the following explanation of the legal bases we rely on to process your Personal Information and a description of your privacy rights.

Legal Bases for Processing

The legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

Consent

We will process your Personal Information based on your consent such as when you create an account or when you ask us to send certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

Our Legitimate Interests

We will process your Personal Information if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. This includes, for example, when we process your Personal Information to carry out fraud prevention activities and activities to increase network and information security, to market directly to you, to expand our business activities, to improve our services and the content and functionality of our Website, and to exercise or defend legal claims (e.g., if you bring a claim against us or we bring a claim against you, we may process your Personal Information in relation to that claim).

To Perform a Contract

We will process your Personal Information to administer and fulfill contractual obligations between us and you.

To Enable Us to Comply with a Legal Obligation

We will process your Personal Information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts and to comply with legal process.
If you have any questions about or need further information concerning the legal basis which we rely upon to collect and use your Personal Information for any specific processing activity, please contact us via the methods in Section 10 “How to Contact Us.”

Your Rights

Access Your Personal Information

You have the right to obtain from us confirmation as to whether or not we are processing Personal Information about you and, if so, the right to be provided with the information contained in this Notice. You also have the right to receive a copy of the Personal Information undergoing processing.

Rectify Your Personal Information

You have the right to ask us to rectify any inaccurate Personal Information about you and to have incomplete Personal Information completed.

Restrict Our Use of Your Personal Information

You have the right to ask us to place a restriction on our use of your Personal Information if one of the following applies to you:

You contest the accuracy of the information that we hold about you, while we verify its accuracy;
We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
You have objected to our using your information, while we check whether our legitimate grounds override your right to object

Object to Our Use of Your Personal Information

You have the right to object to our use of your Personal Information where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).

Delete Your Personal Information

You can ask us to delete your Personal Information if:

We no longer need it for the purposes for which we collected it;
We have been using it with no valid legal basis;
We are obligated to erase it to comply with a legal obligation to which we are subject;
We need your consent to use the information and you withdraw consent;
You object to our processing your Personal Information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with Section 6 “Data Retention.”

If you do exercise a valid right to have your Personal Information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Transfer Your Personal Information to Another Service Provider

You may request that we transfer the Personal Information you have provided us with to you or another service provider in electronic copy. This applies to Personal Information we are processing to service a contract with you and to Personal Information we are processing based on your consent.

To exercise any of these rights, please contact us as described in Section 10 “How to Contact Us.”

Make a Complaint

If you have any concerns or complaints regarding our processing of your Personal Information, please contact us as described Section 10 “How to Contact Us” and we will do our best to answer any question and resolve any complaint to your satisfaction.

If, for whatever reason, you feel we do not meet the standards you expect of us, you also have the right to make a complaint to your local supervisory authority:

EU Data Protection Authorities (DPAs) whose contact information is available here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
Swiss Federal Data Protection and Information Commissioner (FDPIC) whose contact information is available here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html
Information Commissioner’s Office (United Kingdom) whose contact information is available here: https://ico.org.uk/global/contact-us/

Web Analytics

As discussed in Section 2 above, our Website uses Google Analytics (“Google”), a web analytics service provided by Google Inc., to analyze and regularly improve the use of the Website.
[We use the function ‘anonymizeIP’ (so-called IP-Masking). Only in exceptional cases will the whole IP address first be transferred to a server in the United States and truncated there. The IP anonymization is active on the Website. The IP address that your browser conveys within the scope of this web analytics service will not be associated with any other data held by Google.]

During your visit to our Website, the following data may be collected:

The pages you call up (i.e., your “click behavior”);
Achievement of “goals” (i.e., conversions);
Your user behavior (e.g., clicks, time spend, bounce rates);
Your approximate location (region)
Your IP address (in abbreviated form);
Technical information about your browser and the end devices you use (e.g., language settings, screen resolution);
Your Internet provider; and
The referrer URL (the website/advertising medium from which you came to this Website).

On our behalf, Google will use this information to evaluate your (pseudonymous) use of our Website to compile reports on the activities. The reports provided by Google are used to analyze the performance of our Website.
The recipients of the data is Google. More information about the contractual arrangements for the processing of personal data with Google can be found at https://business.safety.google/adsprocessorterms/ and https://business.safety.google/adscontrollerterms/.

Access by U.S. authorities to the data stored by Google cannot be ruled out.

The information generated by the cookies about your use of our Website will be transmitted to and stored by Google on servers in the United States. For more information about the safeguards implemented by Google for international data transfers, please visit https://business.safety.google/adsprocessorterms/.

To prevent such collection by Google Analytics, you can choose not to consent to the setting of the cookies or, for website-based use, downloading and installing the browser add-on to disable Google Analytics, available at https://tools.google.com/dlpage/gaoptout?hl=en.

You can also prevent the storage of cookies when using our Website by configuring your browser software accordingly. However, if you configure your browser to reject all cookies, this may limit functionality on the Website.

The legal basis for this data processing is your consent. You can withdraw your consent at any time, with future effect, by disabling the cookies in your browser.

It should be noted that Google may use the data described in this section for its own purposes and may link it to other data already maintained by Google.

For more information about Google Analytics’ terms of service and Google’s privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/gb/ and https://policies.google.com/privacy.

International Transfers

International data transfers refers to transfers of personal data outside of the European Economic Area, or, for persons outside of the European Economic Area, outside of the country in which they are based. Your information, including Personal Information, will be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those of your jurisdiction.

We ensure that appropriate safeguards are implemented to secure such data transfers in compliance with applicable data protection laws, including when we transfer your Personal Information from the European Economic Area to our headquarters in the United States.

14. Additional Information for Residents of Australia

Applicable Privacy Requirements

For users accessing the Website in Australia, applicable privacy requirements we comply with include the Privacy Act 1988 (Cth) including the Australian Privacy Principles, the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth), and any mandatory standards or industry codes. In this section of the Privacy Notice, the term “Personal Information” includes the meaning given to “Personal Information” under the Privacy Act 1988 (Cth).

Using Personal Information

If we use your Personal Information to contact you and you would prefer us not to, or if you indicate a preference for a method of communication, please let us know and we will respect your preference. When your choice is to continue to deal with us, we take it that you agree to and consent to our using your Personal Information, provided we follow the approach we explain in this Notice and comply with the law.

Sharing and Disclosing Your Personal Information

Residents of Australia accessing and using the Website are notified that their Personal Information may be held and processed overseas. Overseas countries where your data may be stored include the United States. When we pass on or share your Personal Information in this way, we comply with applicable law and take steps to ensure it is treated in the same way that we would treat it. Where reasonably possible, we seek to work with information and records from which Personal Information has been removed.

Requests for Access to Your Personal Information and Complaints About Privacy

You may wish to contact us to request access to your Personal Information, to seek to correct it, or to make a complaint about privacy. Our contact details are set out in Section 10 “How to Contact Us.”
We will respond to your request for access to Personal Information we hold about you as soon as we reasonably can, even if we are unable to provide you with access (such as when we no longer hold the information).
We do not impose any charge for a request for access, but we may charge you a reasonable fee for our costs associated with providing you with access and retrieval costs.
For complaints about privacy, we will establish in consultation with you a reasonable process, including timeframes, for seeking to resolve your complaint.

15. Additional Information for Other Users

If you are located in a jurisdiction not specifically mentioned above, you may also have certain rights with respect to your Personal Information that we collect as a data controller. For example, you may have the following rights:

Right to access your Personal Information;
Right to receive a copy of your Personal Information, including in a machine readable format;
Right to delete your Personal Information;
Right to update your Personal Information;
Right to correct inaccurate, out-of-date, or irrelevant Personal Information;
Right to anonymization, blocking, or deletion of unnecessary or excessive Personal Information or Personal Information processed in noncompliance with applicable law;
Right to receive information about public and private entities with which we have shared your Personal Information;
Right to information about the possibility of denying consent and the consequences of such denial;
Right to revoke consent;
Right to confirm that we are processing your Personal Information;
Right to restrict our processing of your Personal Information; and
Right to object to or opt out of direct marketing from us.

If you would like to exercise your legal rights, please contact us as described in Section 10 “How to Contact Us.” We will process your request in accordance with any applicable legal requirements.