Privacy Policy


Sterling Financial (“Sterling Financial”, “our”, “us” or “we”), takes steps intended to meet privacy principles and requirements under applicable privacy legislation with respect to personal information. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This Privacy Policy describes how Sterling Financial collects and uses the personal information you provide, or provided on your behalf, or which may be generated or collected when you interact with our website It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. Does not apply to information about our employees or to information that is not personal information.

Personal Information We Collect.

Sterling Financial and its agents and representatives collect personal information about you from various sources (including, without limitation, from credit reporting agencies, creditors, and businesses and financial institutions with which you have had a financial relationship). Personal information we collect includes, without limitation:

  • your name, address, e-mail address, Internet Protocol address, telephone number, date of birth, and other contact information;

  • your business name, address, tax id number, business inception date, business bank statements (and data about your banking transactions), telephone number and address;

  • financial information, such as your bank name and your bank account number, personal and business credit bureau reports, payment behavior, and other reports concerning your credit history and experience;

  • other financial or personal information about you, such as your percent ownership in the business, your liabilities, and your financial condition;

  • your social security number;

  • your identity through an acceptable form of government-issued identification;

  • we may collect data through a third party site inspection vendor, or social media sites or services.

  • information about any previous loan applications you may have previously applied for (directly or on your behalf)

  • such other information we may collect with your consent or as
    permitted or required by applicable law; and

  • personal information about you given to us by others and personal
    information about others provided by you.

Use of Personal Information. We generally use personal information for the following purposes:

  • to verify your identity in connection with our user registration process;
  •  to manage and administer your account with Sterling Financial;
  •  to facilitate the transactional process between financial institutions
  •  to compile and analyze information to better understand our
  •  to produce data analytics and reports containing summaries of data and general information that we may share with business partners.
  • to prevent fraud, identity theft or illegal activities;
  • to maintain our business records for reasonable periods and to generally manage and administer our business;
  • to compare information for accuracy and verify it with third parties; and
  • to meet legal, regulatory, insurance, audit, processing and security requirements imposed on us, which may include establishing and verifying your identity and checking your identity against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies in the United States.

We may also use your personal information in other manners with your consent or as permitted or required by applicable law.

In certain situations, Sterling Financial may be required to disclose personal data in response to lawful requests by public authorities. We reserve the right to disclose your personal information as required by law, such as to comply with a judicial proceeding, court order, or legal process served on our Web site when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Disclosure of Your Personal Information.

We may disclose your personal information to our affiliates for internal audit, management, billing or administrative purposes. In addition, we may disclose your personal information in the following circumstances:

Service Providers.

We may disclose personal information to outside agents, representatives and service providers (including affiliates of Sterling Financial acting in this capacity) that perform services on our behalf, such as website systems operators, credit reporting agencies, banks and collection agencies, live chat, law firms or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy. We take reasonable steps to ensure that personal information we disclose to these outside agents, representatives and service providers is protected and not used or further disclosed for purposes other than as directed by us or as required by applicable law.

Legal, Regulatory, Etc.

We may disclose your personal information as necessary to meet applicable legal, regulatory, industry self-regulatory, insurance, audit and security requirements and obligations, including as required by our outside agents, representatives and service providers.


We may otherwise disclose your personal information only in ways that are described in this privacy policy and with your consent or as permitted or required by applicable law.

The Internet and Our Website.

We operate and control our website at

Tracking Technologies.

We and our partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

We may use “cookie” files to enhance the use of our website and the loan marketplace for our registered users and other users. A “cookie” is a small text file placed on a computer’s hard drive by our web page server in order to recognize that a user has previously visited our website and to apply the configuration preferences that the user has chosen. Other than the information provided by a user, cookie files do not contain information that can be used to identify an individual user. You can disable cookies using your Internet browser’s settings and you should consult your browser’s help function for information on how to disable cookies. Please note that if you disable cookies, certain features of our website may not function properly. We do not require anyone to accept cookies in order to use our website or the loan marketplace.

The use of cookies by our tracking utility company and service providers is not covered by our privacy policy. We do not have access or control over these cookies. Our tracking utility company and service providers use session ID cookies to make it easier for you to view your business address, and provide us with usage tracking for the platform.

We and Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, analytics, and site functionality.

E-mail Policy.

Once you complete our user registration and your Sterling Financial account is created, we will use your e-mail address as
one method to contact you regarding your Sterling Financial account. We may also contact you at any telephone number, or physical or
electronic address to collect and may include SMS messages (including text messages), calls using prerecorded messages or artificial voice

No Third-Party Marketers.

We do not sell, rent or trade your personal information to third parties or marketing firms for their promotional
purposes. We do send communications periodically to inform you of the status of transactions or events related to your Sterling Financial
account and your use of our website. Receiving emails from our website is part of our service. If you no longer wish to receive these emails, you
may opt out of them by unsubscribing or by contacting Customer Service.

Your Consent.

Your consent to the collection, use and disclosure of personal information may be given in various ways. Your consent can be express (e.g., orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (e.g., when you provide information necessary for a service or transaction you have requested). In certain circumstances, you may provide your consent where notice has been provided to you regarding our intended use of your personal information and you have not withdrawn your consent for the intended use (e.g., when you do not elect an “opt-out” option). Your consent may also be given by your authorized representative, such as your legal guardian or a person having a power of attorney.

Generally, by providing us with your personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection.

We collect, use and disclose your personal information with your consent, except as permitted or required by applicable law. We may be required or permitted under certain statutes or regulations to collect, use or disclose personal information without your consent, including, without limitation, to comply with a court order, local or federal regulations or a legally permitted inquiry by a government or law enforcement agency, or to collect a debt owed to us, our agents, representatives and service providers, or another registered user.


We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include secure web pages, encryption, password intrusion detection systems and firewalls as described below.

Secure Web Pages.

All of the pages on our website that ask for your personal information are transferred to your browser through HTTPS, a secure server communications protocol.


When you send your personal information to us, it is protected by SSL (Secure Sockets Layer) Technology. SSL does not allow anyone to read your personal information. When you transmit your information to us, SSL encrypts it (translates the data into a string of gibberish characters) and only we can decode the encryption.

Firewall Protection.

Your financial information is encrypted and backed up every day. In the unlikely event that our website is “hacked” your data will remain secure. These safeguards are used to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification of your personal information. Our authorized employees, agents and parties to a contract of work or services with us who require access to your personal information in order to fulfill their job requirements or contracts will have access to your personal information.

Access, Correction and Contacting Us.

Upon request, Sterling Financial will provide you with information about whether we hold any of your personal information.

We may establish and maintain a file of your personal information for the purposes described in this Privacy Policy. You may request access to your file or correction of any inaccuracies in your personal information in our possession, or held by the personal information agent who prepared a credit report on you. Your right to access or correct your personal information is subject to applicable legal restrictions. If you wish to request access or correction of your file, request that we no longer use your information to provide you services, or to make inquiries or complaints or have other concerns about our personal information practices, you may e-mail us at We will respond to your request within a reasonable timeframe.

Data Retention.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements

Note Regarding Children Under 18.

Users of our website and loan marketplace must be U.S. residents that are 18 years of age or older. Additional requirements apply to registered users.

Helpful Tips on Protecting Your Personal Information.

Set forth below are several tips intended to help you protect your personal information:

Identity Theft.

If you think your identity has been stolen, contact all three credit-reporting agencies listed below to put a fraud alert on your credit report:

  • TransUnion ( Phone: 1-800-680-7289 E- mail: Mail: TransUnion P.O. Box 6790 Fullerton, CA 92834
  • Equifax ( Phone: 1-888-766-0008 E-mail: Mail: Equifax Credit Information Services, Inc P.O. Box 740241 Atlanta, GA 30374
  • Experian ( Phone: 1-888-397-3742

After you contact all three credit-reporting agencies, you should check your credit report again in 30 to 60 days for any new signs of identity theft or records that still need to be removed. You should also file a police report with your local enforcement agency. A police report is helpful when dealing with creditors as you challenge inquiries to your credit report or accounts opened fraudulently in your name. You should also keep records of all actions you have taken and letters you have written regarding your identity theft.


Restrictions on Offer and Solicitation and Distribution

This Site is not directed at, or intended for distribution to or use by, any person or entity that is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation or which would subject Sterling Financial to any registration or licensing requirement within such jurisdiction. Nothing on this Site shall constitute an offer or a solicitation of an offer to buy or sell any products or services, including but not limited to any financial instruments or other investments or investment advice. The information in the Site is descriptive of Sterling Financial as a whole and the services, financial instruments described may not be suitable for you or available in the jurisdiction in which you are located, or may only be available through a branch or an affiliate of Sterling Financial that is properly licensed to offer such services, securities or financial instruments in such jurisdiction.

Sterling Financial will not treat users of this Site as its clients by virtue of them accessing it. Users of this site should seek the advice of their independent financial adviser prior to taking any investment decision on the basis of any information contained herein and no information herein constitutes general or specific investment, legal, tax or accounting advice of any kind.
The information contained on this Site may relate to the products and services of a person or entity that is located in a jurisdiction other than that in which you are located. Accordingly the rules for the protection of private customers that apply in the jurisdiction in which you are located may not apply in relation to such products and services.
This Site has not been created for any particular investor or client or for any particular type of investor or client.

No Guarantee

There is no guarantee that the investment objectives discussed on this Site will be achieved. No representation is made that Sterling Financials’ risk management, investment process or investment objectives will or are likely to be achieved or successful or that a client or investor will make any profit or will not sustain losses. Past performance should not be construed as an indicator of future results. Future returns are not guaranteed and loss of principal may occur.

Descriptions of Process

Any descriptions or information involving investment objectives or criteria, investment process, or investment strategies are provided for illustration purposes only, may not be fully applicable to each client or investor, may not be fully indicative of any present or future investments, may be changed in the discretion of Sterling Financial and are not intended to reflect actual performance or to project performance.

Forward-Looking Statements

Any assumptions, assessments, intended targets, statements or the like (collectively, “Statements”) regarding future events or which are forward-looking constitute only subjective views, outlooks, estimations or intentions, are based upon Sterling Financials’ expectations, intentions or beliefs, should not be relied on, are subject to change due to a variety of factors, including fluctuating market conditions and economic factors, and involve inherent risks and uncertainties, both general and specific, many of which cannot be predicted or quantified and are beyond Sterling Financials’ control. Future evidence and actual results (including actual composition and investment characteristics of client or investor portfolios) could differ materially from those set forth in, contemplated by, or underlying these Statements. In light of these risks and uncertainties, there can be no assurance and no representation is given that these Statements are now or will prove to be accurate or complete in any way.
Sterling Financial undertakes no responsibility or obligation to revise or update such Statements.




Descriptions of investment objectives or criteria, investment processes, or investment strategies are provided for illustration purposes only.

Past performance should not be construed as an indicator of future results. Descriptions or information involving investment objectives or criteria, investment process, or investment strategies are provided for illustration purposes only.
Forward looking statements constitute only the views and expectations of Sterling Financial and are subject to change.
Nothing on this Site shall constitute an offer or a solicitation of an offer to buy or sell any products or services, including but not limited to any securities, financial instruments or other investments or investment advice.