Privacy Notice

Sterling Group, L.P.
Sterling Group Partners IV, L.P.,
Sterling Group Partners IV (Parallel), L.P.,
Sterling Group Credit Fund, L.P.,
Sterling Group Credit Fund (Parallel), L.P.,
Sterling Group Credit Fund II, L.P.,
Sterling Group Credit Fund II (Parallel), L.P.,
Sterling Group Foundation Fund, L.P., and
Sterling Group Foundation Fund (Parallel), L.P.
February 22, 2024

Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our individual limited partners and clients. We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you this privacy notice (the “Privacy Notice”) to help you better understand why and how we collect certain personal information, the care with which we treat that information, and how we use that information.

Information We Collect: In connection with forming and operating our private investment funds and/or performing asset management services for our investors and clients, we collect and maintain the following categories of non-public personal information:

  • Contact information: name, address, email address and telephone number;
  • Identification information: signature, date of birth, place of birth, citizenship, location of residence, social security number, taxpayer identification number, driver’s license, passport and other government identification and numbers;
  • Background information: information required to perform, or revealed in, know-your-customer (KYC) and anti-money laundering (AML) due diligence, investor accreditation and consents;
  • Financial information: assets, income, net worth, amounts and types of investments, risk tolerance, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax status and information;
  • Investment information: information about your interest in the relevant investment, including ownership percentage, capital investment, income and losses; and
  • Technical or account information: electronic device and usage information (for example, from cookies and similar technology), registration information and online account data.

Sources of Non-Public Information: We collect personal information from the following sources:

  • Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications, or in subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation); and
  • Information about your transactions with us or others, and
  • Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies” and/or similar technologies.

Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:

    1. performing services to you, including but not limited to:
      1. the administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
      2. ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
      3. the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
      4. ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
      5. keeping investors informed about the business of the general partner of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
      6. facilitating the execution, continuation or termination of the contractual relationship between an investor and the general partner, the fund(s) and/or other applicable party;
      7. facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner, the fund(s) and/or any other applicable party;
    2. auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
    3. maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
    4. enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
    5. facilitating business asset transactions involving the funds;
    6. complying with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure of Information: We may disclose any of the categories of personal information set out in the “Information We Collect” section above as permitted or required by law or regulation and to affiliates and service providers including but not limited to, administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

Former Investors and Clients: We maintain non-public personal information of our former investors and clients and apply the same policies that apply to current investors and clients.

Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your non-public personal information in our possession or under our control.

Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. In the event that we do so, we will make an updated version of this Privacy Notice available to you via the investor portal. The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice complies with the relevant provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you, including as set forth in our additional privacy notices.

Contact Us: If you have any questions or concerns about this Privacy Notice or wish to exercise any rights, submit requests, or appeal any of our decisions in connection with this Privacy Notice (each, a “Communication”), or to view this Privacy Notice in an alternate format, please contact us at 888-508-1831 or via email at: privacy@sterling-group.com.

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.


¹This Privacy Notice is intended only for individuals and certain entities that are essentially “alter egos” of individuals (e.g., revocable grantor trusts, IRAs or certain estate planning vehicles).

 

PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS

This notice (the “California Privacy Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Privacy Notice is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

Category Examples Collected
A. Identifiers Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and drivers’ license or state identification card number). YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). YES
C. Protected classification characteristics under California or federal law Date of birth, citizenship and birthplace. YES
D. Commercial information Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). YES
E. Biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. NO
F. Internet or other similar network activity Use of our website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries. YES
G. Geolocation data Physical location or movements. NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below) Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. YES, as to the following types of information: social security, driver’s license, state identification card, or passport numbers; account log-in, financial account in combination with any required security or access code password; or credentials allowing access to an account only.

 

We do not collect or use sensitive personal information other than:

  • To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
  • As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
  • For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
  • To perform services on behalf of our business;
  • To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

We collect personal information for the business or commercial purposes and from the sources set forth in “Purposes for Collecting Personal Information” and “Sources of Non-Public Information,” respectively, in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Information We Collect” section of this California Privacy Notice only as long as is reasonably necessary for those business or commercial purposes set forth in “Purposes for Collecting Personal Information” in the Privacy Notice above, except as may be required under applicable law, court order or government regulations.

Disclosure of Information: Within the last twelve (12) months, we have disclosed personal information collected from you for a business or commercial purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category Category of Third-Party Recipients
A. Identifiers Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information N/A
F. Internet or other similar network activity Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data N/A
H. Sensory data N/A
I. Professional or employment-related information N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) N/A
K. Inferences drawn from other personal information N/A
L. Sensitive Personal Information Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

 

We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Rights under the CCPA

 

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:

  • The categories of personal information we collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting such personal information;
  • Categories of third parties to whom we disclose the personal information;
  • The specific pieces of personal information we have collected about you; and
  • Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.

Call us using the following toll-free number: 888-508-1831.

Email us at the following email address: privacy@sterling-group.com.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Please contact the privacy@sterling-group.com with any questions about this Privacy Notice.

 

EU AND UK PRIVACY NOTICE

This EU and UK Privacy Notice (“EU and UK Privacy Notice”) applies to the extent that EU and/or UK Data Protection Legislation (as defined below) applies to the processing of personal data by an Authorized Entity (as defined below). If this EU and UK Privacy Notice applies, the relevant data subject has certain rights with respect to such processing of their personal data, as outlined below.

For this EU and UK Privacy Notice, “EU and/or UK Data Protection Legislation” means all applicable legislation and regulations relating to the protection and/or processing of personal data in force from time to time in the EU, the EEA and/or the UK, including, as applicable: (a) Regulation (EU) 2016/679 (the “General Data Protection Regulation”); (b) the General Data Protection Regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018; and (c) any other legislation which implements any other current or future legal act of the EU, EEA or UK concerning the protection and/or processing of personal data and any national implementing or successor legislation, and including any amendment or re-enactment of any of the foregoing. The terms “controller”, “processor”, “data subject”, “personal data”, “processing” and any other applicable term in this EU and UK Privacy Notice shall be interpreted in accordance with the applicable EU and/or UK Data Protection Legislation. Unless the context otherwise requires, as used herein the words “include,” “includes” and “including” shall be deemed to be followed by the phrase “without limitation.” All references to “investor(s)” in this EU and UK Privacy Notice shall be to such actual or potential investor(s) and, as applicable, any of such investor(s)’ partners, officers, directors, employees, shareholders, members, managers, ultimate beneficial owners and affiliates. Unless otherwise defined herein, capitalized terms used in this EU and UK Privacy Notice will have the meanings ascribed to such terms in the applicable Sterling Fund (as defined below) governing documents and/or investor’s subscription agreement (the “Subscription Agreement”) as applicable.

Please contact privacy@sterling-group.com with any queries arising out of this EU and UK Privacy Notice.

Categories of personal data collected and lawful bases for processing

The Sterling Group, L.P. and its affiliates (collectively, “Sterling”) manage a number of private investment funds and other investment vehicles (each, a “Sterling Fund”). In connection with forming, offering and operating each such Sterling Fund, Sterling and its administrators, legal and other advisors and agents (the “Authorized Entities”) collect, record, store, adapt and otherwise process and use personal data either relating to investors and other data subjects from the following sources:

  1. information received in telephone conversations, in voicemails, through written correspondence, via e-mail or on subscription agreements, investor questionnaires, applications or other forms (including any anti-money laundering, identification and verification documentation);
  2. information about transactions with any Authorized Entity or others;
  3. information captured on any Authorized Entity’s website, data room and/or investor reporting portal (as applicable) including registration information and/or any information provided through online forms and/or any information captured via “cookies” and/or similar technologies;
  4. information from available public sources, including from:
    • publicly available and accessible directories and sources;
    • bankruptcy registers;
    • tax authorities, including those that are based outside the UK and the EEA if the applicable data subject is subject to tax in another jurisdiction;
    • governmental and competent regulatory authorities to whom any Authorized Entity has regulatory obligations;
    • credit agencies; and
    • fraud prevention and detection agencies and organizations.

Any Authorized Entity may process the following categories of personal data:

  1. names, dates of birth and birth place;
  2. contact details and professional addresses (including physical address, email address and telephone number);
  3. account data and other information contained in any document provided by investors to the Authorized Entities (whether directly or indirectly);
  4. information regarding the use of any Authorized Entities’ website, data room and/or investor reporting portal;
  5. risk tolerance, transaction history, investment experience and investment activity;
  6. information regarding an investor’s status under various laws and regulations, including their social security number, tax status, income and assets;
  7. accounts and transactions with other institutions;
  8. information regarding an investor’s interest in a Sterling Fund, including ownership percentage, capital commitment, income and losses;
  9. information regarding an investor’s citizenship and location of residence;
  10. source of funds used to make the investment in the Sterling Fund;
  11. anti-money laundering, identification (including passport and drivers’ license) and verification documentation.

Any Authorized Entity may, in certain circumstances, combine personal data it receives from an investor with information that it collects from or about such investor. This will include information collected in an online or offline context. In addition, personal data of investors may be processed and controlled irrespective of whether such investor is admitted to a Sterling Fund.

One or more of the Authorized Entities are “controllers” of personal data collected in connection with the Sterling Funds. In simple terms, this means such Authorized Entities: (i) “control” the personal data that they or other Authorized Entities collect from investors or other sources; and (ii) make certain decisions on how to use and protect such personal data.

There is a need to process personal data for the purposes set out in this EU and UK Privacy Notice as a matter of contractual necessity under or in connection with the governing documents, the applicable Subscription Agreements and any other associated documentation, and in the legitimate interests of the Authorized Entities (or those of a third party) to operate their respective businesses. From time to time, an Authorized Entity may need to process the personal data on other legal bases, including: with consent; to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest.

A failure to provide the personal data requested to fulfill the purposes described in this EU and UK Privacy Notice may result in the applicable Authorized Entities being unable to provide the services in connection with the governing documents and/or applicable Subscription Agreement in relation to each Sterling Fund.

Purpose of processing

The applicable Authorized Entities process the personal data for the following purposes (and in respect of paragraphs (c), (d), (f), (h), (i) and (k) in the legitimate interests of the Authorized Entities (or those of a third party)):

  1. the performance of its contractual and legal obligations (including any applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of investors in a Sterling Fund;
  2. the administrative processes (and related communication) carried out between the Authorized Entities in preparing for the admission of investors to a Sterling Fund;
  3. ongoing communication with investors, their representatives, advisors and agents, (including the negotiation, preparation and execution of documentation) during the process of admitting investors to a Sterling Fund;
  4. the ongoing administrative, accounting, reporting and other processes and communication required to operate the business (including any websites, data room and/or investor reporting portal) of a Sterling Fund and/or any other applicable Authorized Entity including in accordance with the respective governing documents of each such Sterling Fund, applicable Subscription Agreements and other applicable documentation between the parties;
  5. to administer, manage and set up investor account(s) to allow investors to purchase their holdings of shares or interests in a Sterling Fund;
  6. to facilitate the execution, continuation or termination of the contractual relationship between an investor and any Sterling Fund and/or any other Authorized Entity (as applicable);
  7. to facilitate the transfer of funds, and administering and facilitating any other transaction, between an investor and any Sterling Fund and/or any other Authorized Entity (as applicable);
  8. to enable any actual or proposed assignee or transferee, participant or sub-participant of any Sterling Fund or any Sterling Fund’s rights or obligations to evaluate proposed transactions;
  9. to facilitate business asset transactions involving any Sterling Fund;
  10. any legal or regulatory requirement;
  11. keeping investors informed about the business of Sterling and its affiliates generally, including offering opportunities to make investments other than in a Sterling Fund they have already invested in; and
  12. any other purpose that has been notified, or has been agreed, in writing.

The Authorized Entities monitor communications where the law requires them to do so. The Authorized Entities also monitor communications, where required to do so, to comply with regulatory rules and practices and, where not prohibited to do so, to protect their respective businesses and the security of their respective systems.

Sharing and transfers of personal data

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where not prohibited by EU and/or UK Data Protection Legislation, to other service providers, investors, employees, agents, contractors, consultants, professional advisers, lenders, processors and persons employed and/or retained by them in order to fulfill the purposes described in this EU and UK Privacy Notice. In addition, any Authorized Entity may share personal data with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and advisers (where necessary or required by law).

Any Authorized Entity may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in this EU and UK Privacy Notice and in accordance with applicable law, including where such transfer is a matter of contractual necessity to enter into, perform and administer the governing documents of each Sterling Fund and applicable Subscription Agreements, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact privacy@sterling-group.com. For the purposes of this EU and UK Privacy Notice, “Non-Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK (as applicable) in accordance with EU and/or UK Data Protection Legislation to ensure an adequate level of protection for personal data.

Retention and security of personal data

Sterling consider the protection of personal data to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including physical, electronic and procedural safeguards to protect personal data in their possession or under their control. Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations.

Personal data will be retained throughout the life cycle of any investment in a Sterling Fund. However, some personal data will be retained after a data subject ceases to be an investor in a Sterling Fund.

Data Subject Rights

It is acknowledged that, subject to EU and/or UK Data Protection Legislation, the data subjects to which personal data relates have certain rights under EU and/or UK Data Protection Legislation, including: to obtain information about, or (where applicable) withdraw any consent given in relation to, the processing of their personal data; to access and receive a copy of their personal data; to request rectification of their personal data; to request erasure of their personal data; to exercise their right to data portability; and the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfill the purposes described in this EU and UK Privacy Notice, may result in the inability to provide the services required pursuant to the governing documents of each Sterling Fund and/or the applicable Subscription Agreement.

In case a data subject to whom personal data relate disagrees with the way in which their personal data is being processed in relation to the governing documents of a Sterling Fund and/or a Subscription Agreement, the data subject has the right to object to this processing of personal data and request restriction of the processing. The data subject may also lodge a complaint with the competent data protection supervisory authority in the relevant jurisdiction.

A data subject may raise any request relating to the processing of their personal data by contacting privacy@sterling-group.com.