GDPR & Data Processing
Information for residents of the European Economic Area and United Kingdom
1. Data Controller Information
For the purposes of the General Data Protection Regulation (GDPR) and the UK GDPR, the data controller is:
Steven Lawrence LLC
Austin, Texas, USA
Email: stevenlawrencellc@gmail.com
Phone: Available upon request
2. Legal Basis for Processing
Under Article 6 of the GDPR, we process personal data based on the following legal grounds:
Consent (Article 6(1)(a))
We process your data based on your consent for marketing communications, non-essential cookies, and optional analytics. You have the right to withdraw consent at any time.
Contractual Necessity (Article 6(1)(b))
Processing necessary for the performance of joint venture agreements, investment subscription agreements, or to take steps at your request before entering into such contracts.
Legal Obligation (Article 6(1)(c))
Processing necessary for compliance with legal obligations to which we are subject, including SEC regulations, anti-money laundering directives, and tax reporting requirements.
Legitimate Interests (Article 6(1)(f))
Processing necessary for the purposes of our legitimate interests, including network security, fraud prevention, business analytics, and direct marketing (where not overridden by your rights).
3. Your Data Protection Rights
Under the GDPR, you have the following rights regarding your personal data:
Right to Access (Article 15)
You have the right to request copies of your personal data and information about how we process it.
Right to Rectification (Article 16)
You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
Right to Erasure (Article 17) - "Right to be Forgotten"
You have the right to request that we erase your personal data, under certain conditions, particularly where the data is no longer necessary for the purposes for which it was collected.
Right to Restrict Processing (Article 18)
You have the right to request that we restrict the processing of your personal data, under certain conditions.
Right to Data Portability (Article 20)
You have the right to request that we transfer the data that we have collected to another organization, or directly to you, in a structured, commonly used, and machine-readable format.
Right to Object (Article 21)
You have the right to object to our processing of your personal data for direct marketing purposes or where we rely on legitimate interests.
4. International Data Transfers
As a U.S.-based company, we transfer personal data from the EEA/UK to the United States. We ensure appropriate safeguards are in place for such transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission and UK ICO, supplemented by Technical and Organizational Measures (TOMs) to ensure an adequate level of data protection.
5. Automated Decision-Making
We do not use automated decision-making processes, including profiling, that produce legal effects concerning you or similarly significantly affect you. All investment decisions and land evaluations involve human review and decision-making.
6. Data Protection Officer
While we are not currently required to appoint a Data Protection Officer under Article 37 GDPR, we have designated a privacy contact responsible for data protection matters. Contact: stevenlawrencellc@gmail.com
7. Right to Lodge a Complaint
If you are located in the EEA or UK and believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with:
- The supervisory authority in your country of residence
- The Information Commissioner's Office (ICO) in the UK
- The Texas Attorney General's Office in the United States
8. Exercising Your Rights
To exercise any of these rights, please contact us at stevenlawrencellc@gmail.com. We will respond to your request within 30 days. We may need to verify your identity before processing your request.