NOTICE
REGARDING TREATMENT OF CONFIDENTIAL INFORMATION
Sterling
Financial Systems, Inc. (Sterling) recognizes the importance
of protecting the confidentiality and security of our
clients’ personal and proprietary information.
This notice describes Sterling’s privacy policies
and how we treat information we receive.
How We Use and Protect Information
When we evaluate client personal or proprietary information,
we treat such information in a confidential manner.
Sterling maintains safeguards to comply with federal
and state standards to protect each client’s nonpublic
personal and proprietary information. Sterling does
not share any nonpublic personal information with any
nonaffiliated third parties, except in the following
circumstances:
• As necessary to provide the
service that the client has requested or authorized,
or to maintain and service the client’s account;
• As required by regulatory authorities
or law enforcement officials who have jurisdiction over
Sterling, or otherwise required by any applicable law;
and
• To the extent reasonably necessary
to prevent fraud and unauthorized transactions.
We may disclose information under such circumstances
to attorneys, accountants, securities professionals
(including governmental agencies) and others.
Security of Client Information
Sterling restricts access to nonpublic personal and
proprietary information to those employees who need
to know such information to provide services to our
clients.
All Sterling employees are prohibited,
either during or after termination of their employment,
from disclosing nonpublic personal or proprietary information
to any person or entity outside Sterling, except under
the circumstances described above. A Sterling employee
is permitted to disclose nonpublic personal information
only to such other employees who need access to such
information to deliver our services to the client.
Any employee who is authorized to have access to nonpublic
personal information is required to keep and place such
information in a secure receptacle on a daily basis
as the close of each business day. All electronic or
computer files containing such information are password
secured and firewall protected from access by unauthorized
persons. All conversations involving nonpublic personal
or confidential information, if appropriate at all,
are conducted by employees in private, and we take care
to avoid any unauthorized persons overhearing or intercepting
such conversations.
While Sterling employs commercially
reasonable security measures to protect our clients’
data and seeks to partner with companies, which do the
same, we cannot absolutely guarantee the security of
any data transmission over the internet or any wireless
network. Companies and individuals we may hire to provide
support services are not allowed to use personal information
we provide to them for their own purposes. Unfortunately,
no data transmission over the internet or any wireless
network can be guaranteed to be 100% secure, and we
therefore are not responsible for any breach of security
or for any actions of any third parties that may receive
any such information.
Privacy notices
Sterling will provide each client with
initial notice of sterling’s current policy when
the client relationship is established. If, at any time,
Sterling adopts material changes to its privacy policies,
Sterling will provide each existing client with a revised
notice reflecting the new privacy policies.
Access to and correction
of information
Generally, upon a client’s written
request, Sterling will make information about the client
available for the client’s review. Information
collected in connection with, or in anticipation of,
any claim or legal proceeding will not be made available.
If personal information we maintain becomes inaccurate,
or if you need to make a change to that information
please contact the Sterling Administration Department,
so we can update our records.
If you reside outside the United States, please be advised
that our Privacy Policy is intended to comply with the
laws and regulations of the United States, which may
not be the same as the laws of your home country. By
using our services or products, you agree that any personal
information which you provide will be treated in accordance
with the laws of the United States.
|
