Sterling Privacy Notice
Effective: September 1st, 2024.
Sterling Equities Associates, Sterling American Property, Sterling Project Development, Sterling Residential Management, Sterling Commercial Management, and SNY (hereinafter referred to as "Sterling," "we" or "our") value our customers' privacy, which is why we are committed to being transparent about our privacy practices. This Sterling Privacy Notice (hereafter, "Notice") describes the collection, use, and disclosure of your information when you visit our website, use our services, or are a tenant of any property owned or managed by Sterling (hereinafter "Services"). By accessing the Services, and/or providing your information, you are hereby agreeing to the Notice, in addition to the applicable Terms of Use.
As used in this Notice, the terms Personal Data means data that is processed by or on behalf of Sterling that can be associated with or reasonably linked with an identified or identifiable person or household. Personal Data does not include information that does not identify a specific User.
Personal Data We Collect And Use
We collect Personal Data about you directly from you and from third parties. Where we collect data about you from one of these sources, we have outlined the purposes for its collection and the Personal Data collected for that purpose below.
Personal Data You Provide
You may provide us with Personal Data directly through your interactions with us for the following purposes:
inquiries and provide updates, we may collect, directly from you, your contact information, such as name, email address, phone number, and other information you may provide us regarding your inquiries.
number, zip code, any other contact information relevant to our relationship with you, bank account information including bank name, account number, routing numbers, credit card information, or ACH/wire instructions, and social security numbers to conduct due diligence and evaluate business opportunities; develop new investment opportunities; manage, operate and grow our business, administer the Services and manage your or our accounts.
legal processes (such as warrants, subpoenas, court orders, and regulatory or law enforcement requests), we may collect, directly from you, your name, drivers' license,
social security number, passport number, state ID cards, criminal history, email address, company information, job title, or phone number .
Personal Data Provided by Others
We may also collect certain Personal Data about you from third parties for the following business purposes:
bugs and provide technical support, collect payments, we may collect payment details including bank account information, bank name, account numbers, routing numbers, credit card information, ACH/wire instructions, payment confirmation numbers, credit reports, background checks, or criminal histories from third parties. If you are a tenant of any properties owned by Sterling or any of Sterling's clients, we may collect information from the building manager regarding your tenancy, including
d. Other Ways We Use the Information We Collect
We may use the personal information collected from any of the above sources for the following business purposes:
our websites, to investigate, prevent, detect and respond to fraud, unauthorized access, or other potential threats to the rights and safety of any individual or third party, or other unauthorized activities or misconduct.
and claims, and to otherwise establish, defend, or protect rights or interests, including in the context of anticipated or actual litigation.
including fulfilling our financial, tax and accounting obligations, such as audits, assessments, privacy, security, and financial controls, accounting, record keeping and legal functions, any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business.
legal processes (such as warrants, subpoenas, court orders, and regulatory or law enforcement requests).
De-Identified and Aggregate Data
Sterling may de-identify and aggregate data for its business purposes, including but not limited to, to improve the products and features of its Services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes. Where we process De- identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. Sterling may disclose De- identified Data to third parties who commit themselves to maintaining the De-identified Data in de-identified form and not attempt to re-identify the data for any business purpose.
How We Share Personal Data
We may share information about you to third parties as indicated below:
With the other parties to transactions when you use the Services, such as payment processors and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions. This includes payment processors and their service providers. The information might include:
Personal Data, payment information and Account information necessary to facilitate and/or authenticate the transaction;
information to help resolve disputes and detect and prevent fraud; and
aggregated data and performance analytics to help us and our merchants better understand user behavior and to help us enhance user experiences.
In aggregated, de-identified form: We may provide aggregated statistical data to third parties for our own analytics and business purposes. Where we share de-identified data with third parties, we do so in compliance with this Notice.
With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including:
if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
to protect our property, Services and legal rights;
in connection with shipping or mailing of information related to the Services;
to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;
to banking partners/payment processors as required by card association rules;
to credit reporting and collection agencies; and
to support our audit, compliance, and corporate governance functions.
With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account communication with a third-party account or platform.
Children's Privacy
Sterling does not provide services to any person under the age of eighteen (18). And neither this website nor the Services are directed to or intended for any person under the age of eighteen (18).
How We Protect Your Personal Data
We strive to take appropriate security measures to help safeguard your Personal Data from unauthorized access and disclosure. For example, only authorized employees are allowed to access Personal Data, and they may only access it for permitted business functions. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, access controls to our data centers, and information access authorization controls.
While we are dedicated to securing our systems and Services, we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission is completely secure, so your use of our Services and provision of information to us is at your own risk.
Changes To This Notice
We reserve the right to change this Notice prospectively effective upon the posting of the revised Notice and your use of our website indicates your acknowledgement of the Notice posted at the time of use. However, should we update this Notice, we will post a new version online. To the extent any provision of this Notice is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
Contact Us
For questions regarding this Notice or to make a request pursuant to this Notice related to your Personal Data, contact us using any of the following options: