Sterling Group L.P. together with its affiliated funds, separate accounts and management entities (“Sterling Group” or “we” or “us”) is sensitive to the privacy concerns of visitors to our website located at https://sterling-group.com/ (the “Website”). This Website Privacy Policy comprises generally applicable and jurisdiction specific-information and where we refer to the “Privacy Policy” below we mean the general sections of this Website Privacy Policy and/or the applicable jurisdictional privacy policies, as the context so requires. This Privacy Policy is intended to help you better understand why and how we collect certain personal information or personal data when you visit the Website, the care with which we treat that information, and how we use that information. “Personal information” and “personal data” as used in this Privacy Policy have the meanings given to them in applicable data protection and privacy laws, and we use these terms interchangeably below for simplicity.
Scope of this Privacy Policy
This Privacy Policy does not address our privacy practices concerning any personal information we collect on or from our investors other than personal information any investors may provide to us through the Website. We address those practices in separate notices sent to our investors or potential investors. This Privacy Policy also does not apply to any processing of personal data by or on behalf of Sterling Group that is covered by a more specific privacy policy or notice (including, but not limited to, our employee privacy notice).
This Privacy Policy applies when you visit the Website. By using the Website, you acknowledge this Privacy Policy, which may be updated by us at any time. If you do not agree to this Privacy Policy for any reason, please do not use the Website or share your personal information with us as discussed below. Please note that this Privacy Policy applies only to the Website and not to any other website that may be linked to it. We do not control, and are not responsible for, the privacy policies or practices of other persons or entities, including any other websites accessible from or linked to the Website. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.
Jurisdiction-specific Information
In addition to reading the general sections of this Privacy Policy, if you are:
How We Collect Your Information and Categories of Information We Collect
Website Visits: In general, we automatically gather certain information from Website visitors, such as the number and frequency of your visits, through server logs. This information may include the URL of the last
1. This Privacy Policy 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).
and next website you visit, your browser and operating system, your IP address, how long you spend on the Website, and what pages you view there.
Please be advised that the virtual data room portals that can be accessed through links on the Website by investors in funds managed by Sterling Group are maintained by third-party service providers, whose privacy policies apply to those portals and to the personal information you provide in activating and using your account to access those portals. The third-party service providers only inform us of who has access to the portals they operate. We encourage you to review those privacy policies.
Other: We will collect any other personal information from you if you voluntarily provide it through the Website, such as by providing your name, e-mail address and other contact information and personal information to receive further information about us.
Information We Collect Through Automatic Data Collection Technologies
We may use certain technologies for automatic data collection in connection with the Website, including:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website. Please see our Cookies Policy below for more information.
How We Use Your Information: We use the information we collect about you or that you provide to us, including any personal information for one or more of the following business or commercial purposes:
We collect information about you so that we can:
Please note that we may process your personal data in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.
We may also process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
We may use service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and e-mail and providing technical, analytical, and hosting functions for the Website. These companies and individuals (which may include our affiliates) may have access to your personally identifiable information we collect through the Website, as permitted by law and as needed to perform their functions but may not use it for any other purpose. We require that these companies and individuals otherwise keep this information confidential.
If Sterling Group is sold to, merges with or transfers substantially all of its assets to, another entity, Sterling Group has the right to share your personal information with that entity, its affiliates and its advisors, to the extent lawfully permissible.
We may disclose any of the categories of personal information set out in the “How We Collect Your Information and Categories of 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.
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 any personal information you provide through the Website from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use the Website and send us such information at your own risk.
Information regarding how you access the Websites (e.g., browser type, access times, and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies or other similar technologies or tools. This information is used to improve the Websites’ performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of the relevant Website, we will ask you to consent to their use. Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to web sites you visit instructing them not to place cookies on the device running that browser. At this time, we do not currently respond to DNT Signals. For more information about how to do this, please visit your browser ‘Help’ section or visit www.allaboutcookies.org and www.youronlinechoices.eu. If you opt-out of certain cookies (whether by activating Do Not Track features or otherwise not consenting to the placement of non-essential cookies, for example via our cookies pop-up) that may mean that you will not be able to access certain parts of features of our Website.
Our Website places the cookies listed below:
| Cookie | Name | Type/Purpose | Duration |
|---|---|---|---|
| Cookie Banner | cookieyes-consent | CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on their subsequent visits to this site. | 1 year |
| WordPress emoji cookie | wpEmojiSettingsSupports | Supports emoji settings | Session Duration |
Further Information
We reserve the right to revise or supplement this Privacy Policy at any time. In the event that we do so, we post an updated version of this Privacy Policy on this page. The examples contained within this notice are illustrations only and are not intended to be exclusive.
Contact Us
If you have any questions or concerns about this Privacy Policy or wish to exercise any rights, submit requests, or appeal any of our decisions in connection with this Privacy Policy (each, a “Communication”), or to view this Privacy Policy 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 in order to verify your Communication.
Children Under the Age of 18
The Website is not intended to be used by children under 18 years of age. If we learn we have collected or received personal information from a child under 18 through such individual’s use of the Website, we will delete that information. If you believe we might have any information from or about a child under 18 that was collected thorough such individual’s use of the Website, please contact us at privacy@sterling-group.com.
This California Website Privacy Policy supplements the Privacy Policy 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 supplement 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 in the Privacy Policy. 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.
What does this California Website Privacy Policy apply to?
This California Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to us through another means (e.g., as an investor or an employee seeking employment) you will receive a separate privacy notice and that notice will govern that personal information.
What Categories of Information Do We Collect About You?
We collect limited types of personal information through our website, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
| 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 driver’s 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. | NO |
| 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). | NO |
| 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, fund data room and investor reporting portal (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. | NO |
We do not knowingly collect or solicit personal information from anyone under the age of 18.
We do not collect or use sensitive personal information other than:
Some internet browsers have incorporated “Do Not Track” features. Please refer to our Cookies Policy for further information.
We collect personal information for the business or commercial purposes and from the sources set forth in “How We Use Your Information” and “How We Collect Your Information and Categories of Information We Collect,” respectively, in the Privacy Policy above. We retain the categories of personal information set forth above in the “What Categories of Information Do We Collect About You” section of this California Website Privacy Policy only as long as is reasonably necessary for those purposes set forth in “How We Use Your Information” in the Privacy Policy above, except as may be required under applicable law, court order or government regulations.
Who Do We Disclose Your Personal Information To?
We do not share (i.e., disclose to a third party 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.
Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business 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 | N/A |
| D. Commercial Information | N/A |
| E. Biometric Information | N/A |
| F. Internet or other similar network activity | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| G. Geolocation data | N/A |
| H. Sensory data | N/A |
| I. Professional or employment-related data | 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, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
We take measures to protect your personal information as set forth in “Security” in the Privacy Policy above.
Your 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:
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 privacy@sterling-group.com with any questions about this notice (the “California Website Privacy Policy”).
This EU and UK Privacy Policy supplements the general Privacy Policy with respect to individuals located in the EU, the EEA, or the UK, to the extent that EU and UK data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK implementation of the GDPR, and the UK Data Protection Act 2018 (collectively, “EU and UK Privacy Laws”) applies to the personal data processing activities set out in the general Privacy Policy. Information that is required to be disclosed to individuals located in the EU, EEA or UK that is not set out in this EU and UK Privacy Policy is otherwise set out in the general Privacy Policy.
For the purposes of applicable EU and UK Privacy Laws, Sterling Group and/or one or more of its affiliates (collectively, “we”, “our”, or “Sterling Group”) will be a controller of any personal data collected by us. As a “controller” under applicable data protection laws, we are responsible for deciding how we collect and use personal data about you and for the information contained in this EU and UK Privacy Policy.
If you are a natural person in the EU and the EU and UK Privacy Laws apply to you, and have any questions about the EU and UK Privacy Policy, including any requests to exercise your legal rights, you may contact us at 888-508-1831 or via email at privacy@sterling-group.com.
Personal Data We Process
Our general Privacy Policy sets out How We Collect Your Information and Categories of Information We Collect. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.).
How we use your Personal Data
Our general Privacy Policy sets out the How We Use Your Information. We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data, including our legitimate interests, contractual necessity and as required by applicable law, as further set out below:
| Purpose | Legal Basis |
|---|---|
| Performing our contractual obligations that you have requested or agreed with us or the organisation that you work for. | Contractual necessity; and/or our legitimate interest in operating our business |
| Taking all necessary steps before entering into a contract with you or the organisation that you work for. | Contractual necessity; and/or our legitimate interest in operating our business. |
| To obtain advice from our professional advisors, including lawyers and accountants. | Contractual necessity; and/or legal requirement; and/or our legitimate interest in operating our business. |
| To process any specific request you may have made. | Contractual necessity; and/or our legitimate interest in operating our business. |
| To promote and market our services. | Our legitimate interest in operating our business. |
| To keep in touch with you as part of our professional network and to administer your participation in any of our events. | Our legitimate interest in operating our business. |
| To notify you about changes to our services or our Website. | Contractual necessity; and/or our legitimate interest in operating our business. |
| To make suggestions and recommendations to you, or to provide you with updates or other information, about our business and services that may be of interest to you. | Our legitimate interest in operating our business. |
| To conduct our business in an efficient, compliant and profitable manner. | Contractual necessity; and/or our legitimate interest in operating our business. |
| To administer and protect our business and our Website, including to continually improve our services. | Contractual necessity; and/or our legitimate interest in operating our business. |
| To provide you with access to the relevant parts of the website (e.g. Password protected sign-in facility). | Contractual necessity; and/or our legitimate interest in operating our business. |
| To maintain our IT systems and manage hosting of our data. | Contractual necessity; and/or our legitimate interest in operating our business. |
| To identify you. | Legal requirement; and/or our legitimate interest in operating our business. |
| To comply with and enforce applicable legal and regulatory requirements and relevant industry standards, codes, rules and policies. | Legal requirement. |
| To protect against, identify and prevent, fraud, money-laundering, cyber attacks, conduct conflicts checks and prevent theft of our property and other unlawful activity. | Legal requirement; and/or our legitimate interest in operating our business. |
| To facilitate corporate transaction and investment reporting. | Legal requirement; and/or our legitimate interest in operating our business. |
| For litigation management and conducting internal audits and investigations. | Legal requirement; and/or our legitimate interest in operating our business. |
| For keeping a record of your relationship with us. | Contractual necessity; and/or our legitimate interest in operating our business. |
No automated decision-making, including profiling, is used by us when processing your personal data.
Disclosure and Transfer of Personal Data
Our general Privacy Policy sets out how we approach the Disclosure of Information. The personal data that we collect from you may be transferred to, and stored at, a destination outside the EEA or the UK. It may also be processed by staff operating outside the EEA or the UK who work for us or third parties engaged in, among other things, the provision of support services to us. We will take all steps necessary to ensure that your personal data is treated securely and in accordance with this EU and UK Privacy Policy and the applicable EU and UK Privacy Laws. For further information about the safeguards used, please contact us at 888-508-1831 or via email at privacy@sterling-group.com.
Security and Retention of Personal Data
We are committed to protecting the personal data you entrust to us. Our general Privacy Policy sets out our approach to Information Security and how we protect the personal data we collect. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EU and UK Privacy Policy, unless a longer retention period is required by law or other accounting or reporting requirement. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact us.
In some circumstances we may fully anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once our processing of your personal data is no longer necessary, we will securely destroy your personal data in accordance with applicable laws and regulations. In some cases, we will keep your personal data where we need to do so to comply with regulatory requirements or purposes of legal actions or investigations involving Sterling Group and its affiliates.
Your legal rights
To the extent that the EU and UK Privacy Laws apply to you, you may have a right of access to the personal data that we hold about you and to some related information, and there are a number of ways you can control the way in which and what personal data we store and process about you as set out below.
Please contact us if you wish to exercise any of the rights set out above. In the event you do contact us, we may need to verify your identity to allow us to prevent disclosure of your information to an unauthorised person. Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive to help us cover the costs of locating the information you have requested. Alternatively, we may not be able to comply with the request.
We normally respond to requests within one month. Occasionally it may take us longer, if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
How to Contact Us About EU and UK Privacy Matters
If you have any questions or concerns about this EU and UK Privacy Policy or our privacy practices, please contact us at 888-508-1831 or via email at privacy@sterling-group.com.
Updates to this EU and UK Privacy Policy
This EU and UK Privacy Policy may be updated periodically to reflect changes in our personal data practices. We reserve the right to amend this EU and UK Privacy Policy from time to time by updating this EU and UK Privacy Policy. Accordingly, users should review this EU and UK Privacy Policy regularly. If we decide to change this EU and UK Privacy Policy, we will post those changes so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users by posting changes on this page.
Right to complain
You have the right to make a complaint at any time with regards to how your personal data has been processed by us under:
We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO or other relevant supervisory authority, so please contact us in the first instance
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