PRIVACY POLICY

This Privacy Policy is issued by Sterling Financial Management LLC, a Deleware limited liability company located at 32 Cassatt Ave, Berwyn PA 19132 ("Sterling Financial Management").

Introduction

The protection of privacy of those using our services is very important to Sterling Financial Management, and we have implemented policies and procedures to ensure this protection.

This Privacy Policy explains what kinds of personal information we collect from you when you use our services, how we use your personal information, who we might share information with, and your rights in relation to the information we collect, including how you can find out about what personal information we hold about you and how you can complain about our use of your information.

What Information We Collect

We collect information from or about clients when they use our services. We also collect the personal information of users provided to us when clients submit applications.

In this section, we explain the different types of personal information ("Personal Information") that we may collect or hold in relation to you, depending on whether you are a client or a user or other contact of one of our clients:

• We may require your phone number for access to and use of an online profile through our website or client portal. You authorize Sterling Financial Management to send you text messages in connection with your use of and receipt of products and services.
• If you are a user from one of our client organizations, we store your contact information (name, postal address, telephone, fax number, and email address) when you enter that information online either through our website or client portal. If you have signed any documents with us, we may also store your signature.
• If you are a client that has chosen to pay for our services by credit card or direct debit, then we collect your credit card or bank account details when you provide these for payment purposes (and please note that we do not store your credit card information; we substitute your credit card information with a PCI-compliant token to safeguard your details and provide you with maximum security).
• Other details relating to the company or organization that you are an employee of, or are administering the Sterling Financial Management account on behalf of, if that information is reasonably necessary for our activities.
• If one of our clients has sent you a message communication using our services, or you have responded to a message communication from one of our clients, then our client will have provided us with your contact details, which may include your name, postal address, telephone, mobile and fax numbers, and email addresses.
• We may also store Personal Information that our clients have collected from other contacts and uploaded to our online portal.
• If you contact us through our website, online portal, or by email, fax, post, or telephone, we will retain your Personal Information that you provide to us, together with the content of our mutual correspondence, including any emails you send to us.
• If you have requested a trial of our services, our sales team will collect contact information (name, address, telephone number, email address) from you over the telephone or via our website or by email.

How We Use Your Personal Information

We use Personal Information to provide quality commercial financing to our clients. We may use your Personal Information in some or all of the following ways:

• To provide you with access to our website or online portal;
• To provide our products and services to you, including as a recipient or end user of our messaging services;
• To process payments and carry out business administration in relation to your client account;
• To respond to any correspondence from you, including handling any complaints from you;
• To verify your identity and for the process of detecting, investigating, and preventing fraud;
• Through the use of analytics software (including Google Analytics Demographics, Interest Reporting, and third-party audience data) to assess and improve the operation and performance of our website and to understand how users find and use our website;
• To analyze your use of our various services (including product usage, system, and log files) to improve the performance and development of our messaging products;
• To request feedback and enhance our products and services;
• To improve your experience and the experience of other clients and users, and to improve our products and services; and
• To comply with any law, rule, legal decision, or regulation that we are obliged to comply with.

You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Sterling Financial Management, or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud.

We use your Personal Information for the purpose of performing our contract with our client or where we have your consent to do so.

Marketing

We may use your Personal Information so that we, our wholly owned subsidiaries, agents, and contractors can provide you with information about our products and services (including by way of direct mail, telemarketing, email, SMS, and MMS) or request your feedback for promotional purposes.

You always have the right to opt out of receiving such information. If you do not wish to receive any information relating to promotions, new services, and features offered by Sterling Financial Management, please contact Sterling Financial Management's Support team at info@sterlingrto.com.

Links to Third Party Websites

Sterling Financial Management websites may contain links to third-party websites. If you visit a third-party website, then you should read the privacy policy of that third-party site to understand how they collect and use your Personal Information. This Privacy Policy applies solely to the Personal Information collected directly by Sterling Financial Management. We are not responsible for how any third-party website collects or uses your Personal Data.

Cookies

A cookie is a small data file placed on your computer containing standard internet log and visitor behavior information, but not any information that could personally identify you.

For further information, visit www.aboutcookies.org orwww.allaboutcookies.org. You can set your browser not to accept cookies, and the above websites tell you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

We use cookies in the following ways:

• We use Google Analytics, Bing ads, Google AdWords Conversion tracker, and other services that place cookies on a browser across the website to help us analyze website visitor behavior and to increase the website's effectiveness for our visitors. These cookies are set and read by the third-party vendors, such as Google.
• We use a session cookie to remember your login to the Sterling Financial Management website or online portal to improve usability.
• We use Google and Bing Webmasters, data from Google Analytics Demographics, Interest Reporting, and third-party audience data to help us understand how people find and use our site. This statistical data is used to provide better services and more relevant content to our users based on demographic and interest data.
• We use Remarketing with Google Analytics to advertise online, including the Google AdWords tracking cookie. This means we will continue to show ads to you across the Internet, specifically on the Google Display Network (GDN). As always, we respect your privacy and are not collecting any identifiable information through the use of Google's or any other third-party remarketing system. Using the Ads Settings, visitors can opt out of Google Analytics for Display Advertising and customize Google Display Network ads. You can opt out of Bing ads within Bing profile settings.
• We and our third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to:
  • Inform, optimize, and serve ads based on your past visits to our website; and
  • Find out how ad impressions, ad services, and your interactions with these ad impressions and ad services are related to visits to our site.

You may opt out of Google's use of cookies by visiting the Ads Preferences Manager. Also, you can opt out of other third-party vendors' use of cookies by visiting the Network Advertising Initiative opt-out page. You can prevent your data from being collected by installing the Google Analytics Opt Out add-on.

Sterling Financial Management does not share, sell, or rent this information in any way subject to the exceptions outlined in this Privacy Policy.

Sharing Your Personal Information with Third Parties

Sterling Financial Management does not sell your Personal Information to third parties. However, your Personal Information may be shared with third parties in the following circumstances:

• If you have consented to us sharing your Personal Information with a third party (for example, via an opt-in).
• Where we are under a duty to disclose or share your Personal Information to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements or to protect the rights, property, or safety of our clients, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
• Where Sterling Financial Management is of the belief that the client or user has breached its contractual obligations to Sterling Financial Management, including any privacy obligations.
• Where it is essential for a third party to provide their services to us for the operation of our business, in which case Sterling Financial Management will take all reasonable steps to ensure that the third party complies with the terms of this Privacy Policy. Examples of such third parties would be: web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors, and consultants. Sterling Financial Management imposes contractual restrictions on service provider use of your Personal Information.
• To our group companies, employees, and contractors who require use of your Personal Information in order to provide our services.
• If Sterling Financial Management decides to sell, buy, merge, or otherwise reorganize, Personal Information may be transferred in connection with the review or consummation of the transaction, and in that case, Sterling Financial Management will require contractual limitations and other obligations for the protection of Personal Information.

Data obtained through the short code program will not be shared with any third parties for their marketing reasons/purposes.

Security of Your Personal Information

Sterling Financial Management takes all reasonable steps to protect your Personal Information from misuse, interference, loss, and from unauthorized access, modification, and disclosure. Sterling Financial Management's websites and internal information management systems are designed with the aim of preventing Personal Information from being disclosed by any unauthorized means. However, you should note that the inherent nature of the Internet is such that the security of information cannot be guaranteed 100%.

Sterling Financial Management retains Personal Information for as long as necessary for the website and client portal, to provide the products and services, and to otherwise fulfill the purposes for which it was collected, as outlined in this Privacy Policy. Different retention periods apply for different types of Personal Information. Personal Information may be retained for longer periods if there is a valid legal reason to do so. For example, Sterling Financial Management may be required to retain Personal Information by law or court order. To the extent that there is no foreseeable need or use of Personal Information, Sterling Financial Management will use commercially reasonable efforts to delete such information.

Access to and Correction of Your Personal Information

You have the right to access the Personal Information that we hold about you and to ask us to confirm what processing we carry out in relation to your Personal Information. If this information is not accurate, complete, and up to date, you may request that we correct this information. To make a request, please contact Sterling Financial Management's Support team at info@sterlingrto.com. Generally, Sterling Financial Management will not charge a fee for providing access to users; however, we reserve our right to charge a reasonable fee if your request is manifestly unfounded, excessive, or repetitive or if you request further copies of the same information.

In order to access or change users' information online, users are required to log in using their unique user name and password provided to them when establishing their Sterling Financial Management account. In order for users to gain access to their Personal Information over the telephone via Sterling Financial Management Support, users may be required to identify themselves via confirmation of the existing account details held by Sterling Financial Management.

Changes to Our Privacy Policy

By providing Sterling Financial Management with your Personal Information and using the services provided, you consent to the collection, use, and sharing of your Personal Information in the manner described in this Privacy Policy. We may amend this Privacy Policy from time to time. We encourage you to check our Privacy Policy regularly as any changes will take effect when they are made or published on our website, as by continuing to use our services, you will be agreeing to the changes we have made to our Privacy Policy.

Complaints or Questions

If you would like to access or correct your information, please contact our Support team at:

Sterling Financial Management Support

Email: info@sterlingrto.com

If you would like to make a request or complaint, or if you have any other questions about this Privacy Policy, please contact our Customer Care Manager at:

This Privacy Policy was last updated in September 2024