What This Notice Covers
Sterling Trust Company, LLC provides this privacy notice under the Gramm-Leach-Bliley Act and Regulation P, 12 C.F.R. Part 1016. This notice applies to nonpublic personal information about individuals who obtain or have obtained financial products or services from us primarily for personal, family, or household purposes.
Information We Collect
We collect nonpublic personal information about you in the course of providing trust and related services, including information you provide to us, information arising from your transactions and relationship with us or our affiliates, and information we receive from third parties in administering, servicing, or protecting your account or relationship with us.
Information We Disclose
We may disclose all of the nonpublic personal information that we collect, but only as necessary to administer, service, process, protect, or transfer your account or relationship with us, or as otherwise permitted by law.
Reasons We Share Your Personal Information
| Reasons we share your personal information | Do we share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes — such as to process transactions, administer and service your account, maintain records, respond to court orders and legal investigations, prevent fraud, or comply with law | YES | NO |
| For our affiliates’ everyday business purposes — to administer and service your account or relationship across affiliated entities | YES | NO |
| For our affiliates to market to you | NO | WE DO NOT SHARE |
| For nonaffiliates to market to you | NO | WE DO NOT SHARE |
Affiliates and Nonaffiliated Third Parties
Our affiliates are companies under common ownership or control with Sterling Trust Company, LLC, including Sterling Foundation Management, LLC and any other entity that is owned by or under common control with Sterling Trust Company, LLC from time to time. We may disclose nonpublic personal information to affiliates only as described in this notice.
We may disclose nonpublic personal information to nonaffiliated third parties only as permitted by law, including service providers performing services for us under agreements restricting their use and further disclosure of the information; financial institutions, custodians, banks, transfer agents, tax-reporting providers, trust-accounting providers, recordkeeping providers, technology providers, document-management providers, mailing providers, auditors, attorneys, accountants, consultants, and other persons or entities as necessary to administer, service, process, protect, or transfer your account or relationship with us; and government authorities, courts, regulators, law enforcement, or other persons or entities when required or permitted by law.
Former Customers
When you are no longer our customer, we continue to disclose and protect your nonpublic personal information as described in this notice.
Confidentiality and Security
Access to nonpublic personal information is limited to personnel, affiliates, and service providers who need the information to perform their responsibilities. We maintain security practices and procedures designed to protect the confidentiality of nonpublic personal information in accordance with our information security program.
Changes
If we change our disclosure practices in a way that requires a revised notice, we will deliver a revised notice as required by Regulation P.