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Privacy Policy

Date Last Revised: September 2024

Privacy Policy

 

Last Updated: September 2024

 

Section 1 – Introduction.

1.1. Intro. This Privacy Policy describes the Personal Information (as defined below) collected or processed when you interact with Sterling (as defined below). It also explains how your Personal Information is used, shared, and is protected by us, and what choices you have relating to your Personal Information. 

This Privacy Policy governs your privacy rights. We recommend reading this Privacy Policy in its entirety. By using our Website, you consent to this Privacy Policy (and any subsequent amendments). If you do not agree to this Privacy Policy, please do not use our Website. 

We may amend this policy from time to time. We encourage you to review this policy periodically, as changes will be posted on this page. If we make any material changes to this policy we will provide a prominent notice. If you do not agree with the changes, you should not use our Website.

If you have any questions about this Privacy Policy or your Personal Information, please email us at privacy@sterling.ai.  

1.2 Ownership & Services. Our Website is owned and operated by Sterling Data Company LLC, a Delaware limited liability company (“Sterling”, “we” or “us”). Sterling is a company engaged in assisting candidates, campaigns, and nonprofits with fundraising efforts, with a variety of products and services (referred to herein as our “Services”).

1.3 Scope. This Privacy Policy applies to all users of our websites – https://www.sterling.ai/ and https://sterlingdatacompany.com/ and https://www.sterlingstrategies.co/ (each, a “Website”). This Privacy Policy also applies to your information that we have acquired, by license or ownership, from third parties. We collect certain information, including Personal Information, from our third-party sources.

1.4 Third-Party Websites. Our Website may contain links to third party sites that are not owned or controlled by Sterling. Please be aware that we are not responsible for the practices of such other sites. We encourage you to read the privacy statements of every third-party website that you visit as these websites have no affiliation with Sterling and may have privacy policies that contain different terms from what is included here. 

Section 2 – Information We Collect.

2.1 Information Provided by You. You have provided us information through various means. We collect “Personal Information”, which identifies you as an individual, or you as an entity. The information we collect may include the following: name, address, email address(es), age, political party affiliation, past donor history, and inferences drawn from any or all of the foregoing. This information is collected directly from you when you sign up for a user account on our Website. This information may be provided by your filling out forms on our Website. This includes information provided at the time of services. We may also ask you for information when you report a problem with our website. In addition we collect information provided by you in the records and copies your correspondence (including email addresses) if you contact us.    

2.2 Information We Collect from You. We collect certain information automatically as you use our Website, including your Internet Protocol address, browser type, computer type, type of mobile device, mobile carrier, computer operating system, the site from where you navigated to our Website, the time and date of using our Website, how long you use (or have used) the Website and the pages that you view. We may also collect your information from third parties, for example, our business partners.

2.3 Cookies. When you visit or use our Website, we may send one or more “cookies” to your computer or other device. Cookies are small files stored on your web browser when you visit our website. Some cookies last only as long as you remain on the website; others, called “persistent cookies” may be stored for longer periods of time. These cookies can make browsing easier by storing your password or your preferences regarding how you use the website. A cookie allows that site to recognize your browser. Cookies collect information such as the IP address of your computer, your browser settings, and information about how you use the website. Your general location may be estimated from your IP address. Some cookies track users’ activity on our website, apps, and services in order to deliver personalized advertising to you on this and other websites. 

If you would like to opt out of cookies, you may change the settings on your web browser to reject or delete cookies. You may also find more information about cookies, including how to opt out of interest-based advertising, at www.cookiesandyou.com. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do, some Website features may not function properly without cookies. 

We use cookies for a number of reasons, including without limitation:

  • Authenticating and identifying you on our Websites so we can provide you the services you requested; 
  • Keeping track of information you have provided to us; 
  • Remembering your preferences or where you left off; 
  • Measuring your use of our Website so we can improve its quality; and 
  • Understanding what you may be interested in.  

Read more about our cookie policy here. 

2.4 Pixel Tags. We may use “pixel tags,” which are small graphic files that allow us to monitor the use of our Website. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. 

2.5 Physical Location. We may collect the physical location of your device by, for example, using satellite, cell phone tower, or Wi-Fi signals. We may use your device’s physical location to better understand who you are. 

2.6 Age Restriction.  Our Website and our Services are not intended for or directed to children under the age of thirteen (13) and we do not knowingly collect Personal Information from children under the age of thirteen (13) on our Website. If we become aware that a child under the age of thirteen (13) has provided us with Personal Information, we will delete the information from our records.

2.7: Sensitive Information. Unless specifically requested, we ask that you not send us, and you not disclose on or through our websites or otherwise to us sensitive personal Information unless specifically requested by us or required by law. 

Section 3 – How Sterling Uses Your Information.

3.1 To Provide Services and Information. As described above, we collect or have collected information from you so that we can effectively offer our Services to you, for data or analytic reasons, data trends, usage, to determine the effectiveness of our Services, or any reasonable reason(s) now or hereinafter adopted. 

3.2 Our Business Purposes. We may also share your information with our clients who may be political campaigns, political organizations, NGO’s, non-profits, and other persons or entities looking for fundraising, financing, or similar services. We may also use your information for our Services and other reasons such as data analysis, developing new Services, sending marketing campaigns, enhancing, improving or modifying our Website, identifying usage trends, determining the effectiveness of our campaigns and any reasonable reason(s) now or hereinafter adopted. 

3.3 Other Purposes. We may use non-Personal Information for other purposes, except when not permitted by applicable law. We may use analytics services, such as Google Analytics, on our Website, our social media pages, or our mobile Website to help us evaluate and analyze how visitors use our Website. For specific details on how Google collects and uses information on our Website, social media pages, or mobile applications, please visit Google’s website. 

Section 4 – How Your Information is Shared.

4.1 Data Broker Services. Please be aware that Sterling is a data broker. We buy, sell, and license the sale of Personal Information. 

4.2 Our Third-Party Service Providers. We may share your information with our third-party service providers, who provide services including, without limitation, website hosting, data analytics, payment processing, customer service, email delivery services, or other services that are used in connection with the Services that we offer. 

4.3 Legal Requests or Requirements and to Prevent Harm. We reserve the right to disclose your Personal Information and any other information collected by you as required by law or when that disclosure is necessary to protect our rights, the rights of a third-party, or to comply with a judicial proceeding or otherwise. 

4.4 Transfer of Your Personal Information. As a data broker, we reserve the right to transfer your information to another person or entity, with or without consideration, unless you opt-out (see below) or unless barred by applicable law. We also reserve the right to transfer your information in the event of a sale of Sterling.  

4.5 Other Sharing of Non-Personally Identifiable Information. We may share non-personally identifiable information with third parties unless you opt-out or unless barred by applicable law.

4.6 Data Aggregation. Sterling will also aggregate, store, and generate insights about our users through the collection and combination of data from many or all users at once (herein “Aggregated Data”). Aggregated Data is derived from personal or use data of our users but does not directly or indirectly reveal the identity of specific users. Instead, Aggregated Data allows us to look at our users, as a whole or in part, to collect information, generate insights, create reports, as well as other statistical analysis in order to improve our business and for other purposes consistent with our future or anticipated business. Brief also reserves the right to use Aggregated Data for any purposes permitted under applicable law.

Section 5 – How Long we Retain Your Information

How long we keep Personal Information that we have collected depends on the type of information and the purpose for which it was collected.  After a reasonable period of time or the completion of the purpose for which it was collected, we will either delete or anonymize personal information.

Section 6 – Access to Your Information and Opt-Out.

Subject to applicable law, you may have the right to request access to and receive details about the Personal Information we have collected and maintained about you, update and correct inaccuracies in your Personal Information, and have the Personal Information deleted. These rights may be limited in some circumstances by local law. We may take reasonable steps to verify your identity before granting access or making corrections. To learn about California resident’s privacy rights please see Section 9 “Additional Information if you live in California”. 

Colorado, Connecticut, Oregon Virginia, Texas and Utah, each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information
  • Data portability/right to have a copy of their data in an easily accessible format.
  • Opt-out of personal data processing for targeted advertising and sales. 

Colorado, Connecticut and Virginia also provide their state’s residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose
  • Opt-out of profiling in furtherance of decisions that produce legal similarly significant effects

Oregon provides its state residents with the right to: 

  • Obtain a copy of a list of third-parties of which your information was shared with.

You can opt-out of us using your Personal Information by sending using the form below, or sending an email to the contact listed on our Website or unsubscribing on the communication you receive. If you send us an email, please be sure to provide (i) sufficient information that allows us to verify that you are the person whom we collected Personal Information; and (ii) sufficiently describe your request. Please note if your opt-out request is specific to a particular type of Personal Information. 

Finally, we are not obligated to delete Personal Information if we are unable to verify that you are the person whom we collected Personal Information, if we have reason to believe that you are a bot and not a person, or for any other reason that indicates that you may not be the person whom we collected Personal Information. 

We will endeavor to comply with your request(s) as soon as reasonably practicable, which may depend on the number of requests we have received at or around the time of your request. If we need additional time, which we reasonably expect to be completed within thirty (30) days, we will contact you in writing and inform you of the reason for the delay. 

Appeals: Under certain state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@sterling.ai. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state’s data protection authority.

If you are a resident of a currently covered jurisdiction, but are submitting the request from a non-covered jurisdiction, there is a chance that your request may be automatically denied. If this is the case, please submit your request in writing noting your state of residence by writing to privacy+geo@sterling.ai

Section 7 – Security of Your Information.

We use industry standard security measures designed to protect your personally identifiable information. However, no data transmission or storage system is impenetrable, and you acknowledge this. If you have reason to believe that the security of your Personal Information might have been compromised, please immediately notify us.

Unless you’re using an encrypted email, we strongly advise you not to communicate any confidential information in your emails to us.

Section 8 – Changes to Our Privacy Policy.

If we decide to change our Privacy Policy, we will post those changes on our Website so that you are aware of what information we collect, how we use it, and under what circumstances we disclose or transfer it. 

We reserve the right to modify this Privacy Policy at any time, so please review the Privacy Policy from time to time. Any changes to this Privacy Policy will become effective immediately upon being made public. 

Section 9 – Additional Information If You Live in California.

Under California privacy laws, including the California Consumer Privacy Act (“CCPA”), we are required to notify California residents about how we use their Personal Information. 

Under the CCPA, “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

We collect the Personal Information in accordance with Section 2, above. 

California residents have the right to opt-out of our sale of their Personal Information by contacting us via email at privacy@sterling.ai, by unsubscribing on the communication you have received, or the form listed on our Website. Please be prepared to provide proof of your residence in California. 

We do not use or transfer Personal Information about California residents under 16 years old without opt-in consent.

We are required to notify California residents, at or before the point of collection of their Personal Information, the categories of Personal Information collected and the purposes for which such information is used.

Verifiable Requests to Delete, and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests, up to twice every twelve (12) months:

  • Right of Deletion: California residents have the right to request that we delete their Personal Information that we have collected about them, subject to certain exemptions. 
  • Right to Know & to Receive a Copy: California residents have the right to request a copy of the specific pieces of Personal Information that we have collected about them in the prior twelve (12) months and to have this information sent to you via email. 
  • Right to Know & Right to Information: California residents have the right to request that we provide them certain information about how we have handled their Personal Information in the prior twelve (12) months.
  • The Right to Non-Discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. We do not and will not discriminate against you for exercising any of your CCPA rights. 

Submitting Requests. Requests to exercise the right of deletion, right to a copy, or the right to information may be submitted by contacting us via email at privacy@sterling.ai or the form listed on our Website and is also at the end of this policy.. 

You may be asked for more information in order for us to verify your identity when you make a request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Authorizing an Agent You may designate an authorized agent to submit your consumer request on your behalf, so long the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.

Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. We do not and will not discriminate against you for exercising any of your CCPA rights. 

Financial Incentive. We may offer you various financial incentives such as special offers when you provide us with contact information and identifiers such as your name and email address. You may withdraw from a financial incentive at any time by opting out. Generally, we do not assign monetary or other value to Personal Information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the Personal Information is related to the estimated cost of providing the relevant financial incentive(s) for which the information was collected.

Metrics Disclosure. 

During the previous calendar year ending December 2023, Sterling received the following requests from all applicable jurisdictions.

Requests to delete personal information: 6,565

Requests to limit the use and disclosure of sensitive information: 100

Average response time: Average 5 days to respond to a request

California “Shine The Light” Law: California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in this policy. 

Section 10 – Notice for Residents of Nevada.

Nevada law, specifically Senate Bill 220, allows customers who are residents of the state of Nevada to “opt out” of the sale of certain Personal Information, called “covered information.”

You have the right to opt out at any time and direct us not to use or transfer your Personal Information. 

Requests to exercise your right to opt out may be submitted by contacting us at privacy@sterling.ai, unsubscribing on the communication you receive, or the form listed on our Website. 

We will endeavor to comply with your request(s) as soon as reasonably practicable, which may depend on the number of requests we have received at or around the time of your request. If we need additional time, which we reasonably expect to be completed within thirty (30) days, we will contact you in writing and inform you of the reason for the delay. 

Section 11 – Disclaimers. 

Sterling is a data broker. We buy, sell, and license the sale of Personal Information. 

Your Personal Information may have been acquired by our third-party sources and transferred to Sterling in accordance with the privacy policies of our third-party sources. If your Personal Information was acquired by our third-party sources, what we can and cannot do shall be based on, and in accordance with the privacy policies of our third-party sources, which we invite you to read.

Please be advised that we may not be the only person or entity with access to your Personal Information. While we may have acquired your information, including Personal Information from our third-party sources, our third-party sources may have also sold or licensed your Personal Information to other persons or entities, or may still be in possession of your Personal Information. It is conceivable, if not likely, that if you submit a request for us to delete your Personal Information, and we do, that your Personal Information may be in the hands of multiple persons or entities, and that you may need to contact each person or entity to prevent your Personal Information from being sold. We may have no relationship with and may be ignorant of the names of other persons or entities who have access to your Personal Information. Thus, we shall only be responsible for your Personal Information with Sterling and not of third parties. 

 

Privacy Opt-Out Request Form