Privacy Policy

Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our clients. We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you this 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 (or “funds”) and/or performing asset management services for our investors and clients, we collect and maintain the following categories of non-public information:

 

• Contact information: name, address, email, 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, 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 and maintain non-public personal information from the following sources:

 

• Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email and other electronic communications, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documentation),
• Information about your transactions with us or others,
• 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.”

 

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

 

• The performance of our contractual and legal obligations (including applicable anti-money laundering, KYC and other related laws and regulations) in assessing your suitability for investing in a fund.
• 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 relevant fund(s) and execution of relate documentation (e.g., the subscription agreement).
• The ongoing administrative, accounting, reporting and other processes and communication required to operate our business and/or the relevant fund.
• To administer, manage and set up your investor account(s) to allow you to purchase your holding (of shares) in the relevant fund(s).
• To facilitate the execution, continuation or termination of the contractual relationship between you and the Partnership and/or the relevant fund (as applicable).
• To facilitate the transfer of funds, and administering and facilitating any other transaction, between you and the relevant fund.
• To audit and perform verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance.
• To maintain the safety, security and integrity of our products and services, databases, technology assets and business, including to detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity.
• To enable any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions.
• To facilitate business asset transactions involving the relevant fund.
• To fulfil any legal or regulatory requirement.
• Keeping investors informed about our business generally, including offering opportunities to make investments other than in the relevant fund.
• Any other purpose that has been notified, or has been agreed, in writing.

 

Disclosure of Information: We may disclose any of the categories of personal information in the “Information We Collect” section above, in connection with fund and/or advised account transactions, partner financial or other reports, or for other purposes relating to raising and managing our funds and overseeing their investments to third parties and our financial service or non-financial service affiliates, including:

 

• Financial service providers, such as broker-dealers, custodians, banks, lenders and others used to facilitate transactions for investors and clients or our private funds,
• Other service providers to the general partner, the manager, their affiliates and/or our private funds, such as legal, consulting, administration, accounting, auditing or tax preparation services and placement agents,
• Portfolio companies, co-investors in portfolio companies and their respective advisors, if requested in connection with an investment, and
• Other private fund partners, parallel fund partners or investors in alternative investment vehicles in connection with closing documentation, investor reports, financial statements or other investor communications.

 

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

Mobile information shared with the use of the Global Relay application in connection with any business performed for you by Sterling will not be shared with third parties/affiliates for marketing/promotional purposes.  Sterling will not send you text messages without your prior consent, and will include clear out-out procedures so that you can stop receiving such communications at any time.  Notwithstanding anything else in these Terms of Use, to the extent text messaging originator opt-in / opt-out data and consents are collected, such information will be solely used by Sterling’s third party providers to manage the text message opt-in / opt-out procedures.

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 update this Privacy Notice, we will make an updated draft available to you via our investment portal. The examples contained within this notice are illustrations only and are not intended to be exhaustive. This notice is intended to comply with the privacy provisions of Regulation S-P of 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, wish to access this Privacy Notice in an alternative format, or wish to exercise any rights, submit requests, or appeal any of our decisions in connection with this Privacy Notice (each, a “Communication”), please contact us at (203) 226-8711.
 
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.

 

Cookies:  We do not use cookies in the operation of the Site or to collect any information about you.
 
CALIFORNIA PRIVACY NOTICE

This notice (the “California Privacy Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under 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 California Privacy Notice 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 collect or have collected within the last twelve (12) months some or all of the following categories of personal information from individuals:

 

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.	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, 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.	NO
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.	YES, solely with respect to recruiting and employment.
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.	YES, solely with respect to recruiting and employment.
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES, solely with respect to recruiting and employment.
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 care, 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.

 

Purposes for Collecting Personal Information: We collect or disclose personal information for any of the business or commercial purposes set forth in the “Purposes for Collecting Personal Information” section in the Privacy Notice above.

 

We collect personal information from the sources set forth in “Sources of Non-Public Information” in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this California Privacy Notice only as long as is reasonably necessary for those 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: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of personal information we collect about you to third parties.

 

We disclose or, within the last twelve (12) months have disclosed, personal information collected from you 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	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.

 

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 over the last twelve (12) months. 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 California Privacy Notice in an alternative format, please submit a request using any of the methods set forth below.

 

Call us using the following toll-free number: (203) 226-8711.

 

Submit a request online using the following online form: https://www.sterlinglp.com/contact

 

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 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.

 

Please contact us at the email address above with any questions or concerns about this California Privacy Notice.