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Privacy Policy

Date Last Revised: March 2025

 

STERLING PRIVACY NOTICE

Last Updated: March 28, 2025

 

SECTION 1 – INTRODUCTION

1.1 Introduction. This privacy notice (the “Privacy Notice”) describes how Sterling Data Company, LLC (“Sterling,” “we,” or “us”) collects, processes or stores your Personal Information (as defined in Section 2.1). It also explains what choices you have relating to your Personal Information.
This Privacy Notice governs your privacy rights. We recommend reading this Privacy Notice in its entirety. By using our websites (as defined in Section 1.3), you consent to this Privacy Notice (and any subsequent amendments). If you do not agree to this Privacy Notice, please do not use our Website.
We reserve the right to change this Privacy Notice from time to time to reflect our current practices without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Notice. We also recommend you review this Privacy Notice on a regular basis. If you do not agree this Privacy Notice, please do not use the Website or our Services (as defined below) or provide us with any Personal Information.

Please note that most of the Personal Information we hold pertaining to consumers is not collected on this Website (as defined below), but rather through partnerships we have with third parties, including but not limited to data suppliers, business partners, data services providers, agencies and our Clients (as defined in Section 4). We provide this Privacy Notice as a service to consumers and others who want to learn more about the Personal Information we collect and how we use it. If you are particularly interested in understanding what information we collect through this Website, please see Section 2 (Information We Collect). This Privacy Notice addresses both information collected from third parties and through this Website. For information we collect and maintain as a Data Broker (as defined in Section 5), please see Section 4 (Information We Hold & Our Services). For information on how we sell or share as a Data Broker please see Section 5 ( How Your Personal Information is Shared).

If you have any questions about this Privacy Notice or our use of 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 is a company engaged in assisting candidates, campaigns, and nonprofits with fundraising efforts, with a variety of products and services (referred to hereinafter as our “Services”). By using our Services, you agree to the terms of this Privacy Notice.

1.3 Scope. This Privacy Notice applies to all users of our websites: (i) https://www.sterling.ai/; (ii) https://sterlingdatacompany.com/; and (iii) https://www.sterlingstrategies.co/ (each, a “Website”). This Privacy Notice also applies to your Personal 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 your “Personal Information”, which for purposes of this Privacy Notice, unless otherwise required by applicable law, means any information that identifies, relates to, describes, or is reasonably capable of being associated, linked or linkable to you or your household, including any information that is subject to applicable data protection laws. Examples of Personal Information we collect may include the following: your name, address, email address(es), age, location data, employment data, political party affiliation, past donor history, and inferences drawn from any or all of the foregoing. Personal Information does not include information that cannot reasonably be linked to you. This Personal Information is collected directly from you when you sign up for a user account on our Website or fill out other forms on our Website. This includes information provided at the time of services. We may also ask you for Personal Information when you report a problem with our Website. In addition we collect Personal Information provided by you in the records and copies your correspondence (including email addresses) if you contact us.

2.2 Information We Collect or Derive About You Automatically. We may also collect certain Personal Information automatically as you use our Website or our Services, including the Internet Protocol (IP) address associated with your activities on our Website, device ID, pixel tags (as defined in Section 3.3), browser type, computer type, type of mobile device and operating system, mobile carrier, computer operating system, the site from where you navigated to our Website and information about how you use the Website, including the time and date on which you visited the Website, how long you use (or have used) the Website and the pages of our Website that you view (collectively, “Device Information”). We may also collect this type of Personal Information from third parties, for example, our business or advertising partners. The information that we collect automatically may be linked with other Personal Information that we have collected.

2.3 Information We Collect from Third Parties. We may collect Personal Information about you from third-party sources (which may be combined with other Personal Information we have collected about you), such as:

  • Other: we may obtain Personal Information, such as demographic information or updated contact details, from third parties; we may also collect information from public records.

 

Section 3 – HOW WE COLLECT YOUR INFORMATION.

3.1 How We Collect Your Personal Information. We may collect Personal Information about you through the following methods:

  • Directly From You: such as when you access our Website, register to receive marketing and other communications from us, or contact us for customer support purposes.
  • From Third Parties or Public Sources: such as affiliates and other third parties, public sources such as census data and other public records, third-party providers of services to us (e.g., fraud detection, identity verification and security), consumer data resellers, social networks, joint marketing partners and affiliate companies.
  • Related to your use of our Services: including information we collect automatically when you use our Website or interact with us, or information we derive about you and your preferences or interests based on the Personal Information we collect and our interactions with you.

3.2 How We Collect or Derive Information About You Automatically. We may collect or derive Personal Information about your use of our Services, or other interactions with us through the following methods:

Cookies. Cookies are small files stored on your web browser when you visit our Website to collect information about your activities through our Services.

  • 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 most cookies. If you choose to delete cookies, any settings and preferences controlled by those cookies will be deleted and may need to be recreated. If your browser settings are set up as ‘Do Not Track’, the use of cookies and tracking technologies will not apply to you.
  • 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.
  • Read more about our cookie Notice here.

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 device 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 device previously placed by that server.

Physical Location. We may collect information on the physical location of your device by, for example, using satellite, cell phone tower, or Wi-Fi signals.

 

Section 4 – HOW STERLING USES COLLECTED PERSONAL INFORMATION.

4.1 To Provide Services and Information. As described above, we collect or have collected Personal Information from you so that we can effectively offer our Services and communicate with you.

4.2 Our Business Purposes. Sterling manages donor profiles, which consist of contact information for potential donors (“Donor Profiles”). This data is analyzed and categorized to enhance its value and usability for Clients (as defined below). To improve the effectiveness of donor outreach, we organize Donor Profiles based on various attributes such as age, location, donation history, or ideological affiliation.

Clients may request specific types of Donor Profiles that align with their needs, including selecting or excluding certain demographics. Sterling applies data management techniques to refine, update, and enhance these profiles, ensuring they remain accurate and relevant.

We may also sell or share your Personal Information with our clients who may include but not be limited to political campaigns, political organizations, NGO’s, non-profits, and other persons or entities looking for fundraising, financing, or similar services (“Clients”). We may also use your Personal 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.

4.3 Why We Use 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 any information (including Personal 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.

Additionally, Cookies may be used for a variety of purposes such as to understand how visitors interact with our Websites, or to serve advertisements on our Websites or on other third party websites. The use of technologies, such as cookies, constitutes a “sale” of your Personal Information under the California Consumer Privacy Act (CCPA). In addition, we may use your Personal Information in a way that constitutes “sharing” under the CPRA. You can opt out of the “sale” or “sharing” by using the “Do Not Sell My Personal Information” link at the bottom of our Website and selecting your preferences below, or broadcasting the global privacy control signal for browsers and extensions that support it. Note that due to technological limitations, if you visit our Website from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences and/or rebroadcast the signal.

4.4 Why We Use Your Device Information. We may use your Device Information (as defined in Section 2.2 above) to better understand who you are and for other purposes described in this Privacy Notice.

4.5 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 5 – HOW YOUR PERSONAL INFORMATION IS SHARED.

5.1 Data Broker Services. Please be aware that Sterling is a data broker (“Data Broker”), meaning we may sell or share your Personal Information to our Clients for the purposes described in this Privacy Notice. For purposes of this Privacy Notice, “sell” means the sale or transfer of your Personal Information to a third party for monetary or other valuable consideration, subject to certain exceptions in applicable law. For purposes of this Privacy Notice, “share” means transferring, making available, or otherwise disclosing your Personal Information to another party for purposes of sending advertising to you based on your Personal Information obtained from your activities across distinctly-branded sites.

5.2 Our Third-Party Service Providers. We may share your Personal Information with our third-party service providers, who provide services to us 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.

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

5.4 Change in Business Ownership or Structure. We reserve the right to transfer your Personal Information if ownership of all or substantially all of Sterling changes through a merger, consolidation, acquisition, asset sale or other corporate reorganization including transfer between Sterling’s entities. You expressly consent to Sterling transferring your Personal Information to the new owner or successor entity, so that we can continue to provide our Services. If required by applicable law, we will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under the applicable data protection laws. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information in the same manner as described in this Privacy Notice.

5.5 Transfer of Your Personal Information. As a Data Broker, we reserve the right to transfer, sell and license your Personal Information to another person or entity, with or without any consideration to you, unless you exercise your opt-out rights in accordance with applicable law (see below) or unless such transfer, sale or license is barred by applicable law. We also reserve the right to transfer your Personal Information in the event of a sale of Sterling.

5.6 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.

5.7 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 (hereinafter “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. Sterling also reserves the right to use Aggregated Data for any purposes permitted under applicable law.

 

Section 6 – HOW LONG WE RETAIN YOUR PERSONAL INFORMATION.

Sterling will store your Personal Information as long as required by law, and where there is no legal requirement, we will only store your Personal Information for as long as necessary to fulfill the purpose for which the Personal Information was collected, including but not limited to the business and commercial purposes described in this Privacy Notice (including the California Residents section) or any other notice provided at the time of collection. How long we keep your 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 your Personal Information.

 

Section 7 – SECURITY OF YOUR PERSONAL INFORMATION.

Whenever Sterling handles information that you enter on our Websites, regardless of where this occurs, we take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. We also use industry standard security measures designed to protect your personally identifiable information. However, no data transmission or storage system over the internet can guaranteed to be one hundred percent (100%) impenetrable. As a result, while Sterling strives to protect your Personal Information, we cannot guarantee, ensure or warrant the security of any Personal Information you transmit to us. You understand and agree that you transmit such Personal Information at your sole risk. If you have reason to believe that the security of your Personal Information might have been compromised, please immediately notify us.
Unless you are using an encrypted email, we strongly advise you not to communicate any confidential information in your emails to us at privacy@sterling.ai

 

Section 8 – SENSITIVE PERSONAL INFORMATION.

Unless specifically requested by us, we ask that you not send us, and you not disclose on or through our Websites or otherwise to us “Sensitive Personal Information,” which includes the following information: (i) your social security number; (ii) driver’s license number or other government-issued identification number; (iii) financial account number; (iv) any health insurance or medical identification number; (v) political affiliations and/or opinions; (vi) an account password; (vii) security questions and answers; or (viii) unique biometric data. We do not knowingly collect Sensitive Personal Information, nor do we use it to infer characteristics about you unless specifically requested by us or required by applicable law.

 

Section 9 – CHILDREN’S PRIVACY.

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 you are a person under the age of thirteen (13), we do not want to receive, collect or store any Personal Information about you, including but not limited to your name, address or email address. 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 as quickly as reasonably possible.

 

Section 10 – CALIFORNIA PRIVACY RIGHTS.

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 (Information We Collect), 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 sixteen (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 two (2) times every twelve (12) months:

  • Right to Request 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.

How to Submit a Request. 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, clicking our “Do Not Sell Link” or the form listed on our Website at: https://sterling.ai/do-not-sell/.

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 the requested 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 the Personal Information you provide to verify your identity or authority in order to fulfill your request. You may only make a request for access or data portability twice within a twelve (12)-month period.

Requests Submitted by an Authorized Agent. You may designate an authorized agent to submit a data subject access right (DSAR) request on your behalf, so long as: (i) the authorized agent has your written permission to do so; and (ii) you have taken steps to verify your identity directly with us. We may request additional information in order to verify that the agent has the authority to submit a request on your behalf, including reaching out to you directly for verification.

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.

The CCPA and the California Delete Act require certain businesses to compile and disclose information regarding their compliance with the CCPA for the previous calendar year. The statistics provided below relate to requests made by or on behalf of California consumers to Sterling

Statistics for the reporting period of January 1, 2024 – December 31, 2024, are as follows:

Requests to Know: 2 Received, 0 Completed, 2 Rejected
Requests to Opt-Out 7369 Received, 730 Completed, 6639 Rejected
Requests to Delete: 16 Received, 6 Completed, 10 Rejected
Requests to Correct: 3 Received, 0 Completed, 3 Rejected

Average response time: Average of fifteen (15) days to respond to a request

Rejections of requests were based on a consumer abandoning their request by not verifying their identity when prompted to, or in the event that a request was processed, and it was determined that Sterling did not hold their data at the time.

California “Shine The Light” Law: California Civil Code Section 1798.83, also known as the “Shine The Light” law gives California residents the right 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 such 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 either in email at privacy@sterling.ai or write to us at:

Sterling Data Company LLC
500 Westover Dr. #92215, Sanford, NC 27330

 

Section 11 – NOTICE FOR RESIDENTS OF NEVADA.

Nevada law, specifically Senate Bill 220, allows 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 12 – ADDITIONAL STATE-SPECIFIC PRIVACY DISCLOSURES.

Depending on your state of residency, you have certain rights related to your Personal Information. If you or an authorized agent wish to exercise these rights, you can submit a request using the methods described in Section 10 (California Privacy rights). Sterling respects and processes all requests from states that have active comprehensive data privacy laws at the time of request submission.

 

Section 13 – DISCLOSURE OF THE USE OF AUTOMATED DECISION-MAKING TECHNOLOGY.

We use automated decision-making technology (“ADMT”) solely to enhance, streamline and improve upon the efficiency of our internal business purposes. This technology involves the use of algorithms and machine learning. Our ADMT is not utilized to process, collect, or analyze your Personal Information, meaning that any Personal Information you provide to us is not subject to an automated decision-making process.

 

Section 14 – DISCLAIMERS.

As previously described in this Privacy Notice, Sterling is a “Data Broker”, meaning we buy, sell, and license your 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 strongly recommend that you review. These policies will provide you with important information regarding how your Personal Information is used, maintained and protected by these third parties (if any). If you have any questions or concerns about the privacy policies of such third parties, we recommend that you contain them directly.

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 not have access to the names of other persons or entities who have access to your Personal Information. Thus, we only maintain responsibility for Personal Information you provide to or collected by Sterling and not that which is maintained by third parties.

 

Section 15 – GENERAL.

15.1 Changes to this Privacy Notice. This Privacy Notice is kept under regular review and may be updated from time to time. When we make changes to this Privacy Notice, we will change the “Last Updated” date above. If a material change is made to this Privacy Notice, we may choose to provide notice to you in advance of such change, such as by posting notice of that change on the first page of this Privacy Notice or on our homepage, or by emailing your email address of record with us.

15.2 Changes to your Personal Information. It is important that the information we hold about you is accurate and current. Please keep us informed as soon as possible if your Personal Information changes or is inaccurate during your relationship with us by using the contact details set out below.

15.3 Contact Us. If you have any concern about our privacy practices, please contact us by email at privacy@sterling.ai, or by writing to us at:

Sterling Data Company LLC
500 Westover Dr. #92215, Sanford, NC 27330

Privacy Opt-Out Request Form