Your Privacy is Our Priority.
Effective date: August 2021
PTS, a Delaware limited liability company, maintains this Policy to describe the information we may collect from you, or that you may provide to us when you interact with the Site (defined below) or our Services (defined below), how we use and share that information, and your options with regard to our use of that information.
Scope of the Policy
This Policy applies to information collected through our website (www.sterlingtradingtech.com) (the “Site”) and Sterling Trader® Mobile, including the software application, or service called Sterling Trader, Sterling Trader Mobile, Sterling TM, or Sterling Mobile, and other products or services that display or link to this Policy (collectively, the “Services”).
This Policy is Part of Our Terms of Service
Updates to this Policy
We review our privacy practices from time to time, which are subject to change. We ask that you periodically review this page to remain familiar with the most current version of our Policy. Information collected after the posted effective date will be treated in accordance with the then most current Policy. When this Policy changes, we will update the “Effective date” at the top of the page.
Information We Collect
In certain areas of the Site and Services, we may ask you to submit information that identifies you as an individual (“personally-identifiable information” or “PII”) to us, and we may invite you to request information from us. In addition to any information that you may voluntarily provide, the Site and Services may automatically collect information about you and your use of the Site or Services.
Information We Automatically Collect
We automatically collect information about your interactions with our Site and Services, including information about the device you use to access the Site or Service.
- collect information about how visitors use the Site and the Services (for example, which pages they visit, which links they use, and how long they stay on each page);
- support the features and functionality of the Site and the Services (for example, to save a visitor the trouble of re-entering information already in our database or to prompt the settings they established on previous visits);
- personalize a visitor’s experience when they use the Site and the Services; and
- improve our marketing efforts, including targeted advertising.
We may use both session cookies and persistent cookies. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. The information we collect using cookies and similar technologies may or may not be directly identifying of you, but we may link it to PII that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit our Site or Services, you may be unable to use all of the functionality of the Site or Services if your browser rejects cookies.
Information from Your Computer or Mobile Device. When you access the Site or Services through your computer or mobile device, we may automatically collect certain information from and/or about your device, such as IP address, access dates and times, information about your approximate location (as determined through your IP address), hardware and software information, mobile and computer or hardware device information. This information allows us to understand how you’ve used the Site or Services, and other actions you have taken in connection with your use of the Site and Services. We automatically collect log data when you access and use the Site and Services.
Information You Provide to Us
Account Registration Information. When you sign up the Services, you provide us with your basic contact information, including your name, email address, and postal address. We use this information to better understand who you are and what content might be relevant for you, to communicate with you about your account, and to send you messages about the Services.
E-Mail Content and Newsletters. You may choose to provide us with PII in an email message to one of the addresses listed on our Site or Services or by submitting your information in a “Contact” section of the Site or Services. We use this information to respond to your message, fulfill your order, or to register you for the Services you have purchased, and we may use it to market or promote relevant services to you. If you sign up for an email newsletter, you have the option to unsubscribe at any time. Any information you choose to provide regarding special interests may be used for marketing and promotional purposes. By providing this information, you may receive occasional email messages from STERLING or an affiliated organization.
Payment Information. You may provide payment information, including credit card or financial account information, to pay for our Services through the Site. This information is used only to fulfill the transactional purpose for which you submit it to us and may be processed by a third-party vendor on our behalf. We use a third-party payment processor to take payment for our Services.
Additional Sources of Information. You may provide additional information to us when you request information about our Services. We may receive this information from you through email, the Site or Services, or over the phone. This information may be combined with other information received through the various channels through which you interact with us.
How We Store Information
We use appropriate technical and organizational measures to ensure a level of security that is reasonable and appropriate to the risk of the information we hold. We leverage reputable vendors to assist in the provision of our services. Unfortunately, the transmission of information over the Internet is not without risk, and although we implement appropriate and reasonable methods to protect your PII, we cannot guarantee the security of that information. Any transmission of PII through the Site or Services is at your own risk and we are not responsible for circumvention of our security measures.
Third-Party Analytics Tools
Beyond the information you voluntarily provide to us directly, STERLING utilizes analytics tools, including third-party technologies such as Google Analytics, to collect information and help us understand how visitors engage with our Site. To learn more about Google Analytics, click here. To learn more about how Google uses data collected through partner sites or applications, click here.
Third-Party Advertising Tools
When you use our Site third parties may deliver cookies or other tracking technologies, including web beacons or tracking pixels) to your computer or mobile device for the purpose of tracking your online behaviors across nonaffiliated websites, and to deliver targeted advertisements on other nonaffiliated websites.
How We Use Information
We use the information we collect to provide you the Services, enhance your experience on our Site and Services, to improve our Services, and for marketing and promotional efforts. For more details about how we use information, please see below.
Use of Information You Provide to Us. Generally, we may use information you provide to us through the Site and Services:
- to provide the information, content and Services you request;
- for security or fraud prevention purposes;
- to provide you with effective customer service;
- to provide you with a personalized experience when you use our Site;
- to contact you with information and notices related to your use of our Site or Services;
- to better understand your needs and interests;
- to improve the content, functionality and usability of this Site;
- to improve our Services;
- to improve our marketing and promotional efforts; and
- for any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us.
Please see “Your Choices” below for information about the choices you have about the ways we use the information we collect about you.
Use of Aggregated Information. We may use information gathered through the Site and the Services to create a compiled, aggregate view of the Site’s and Service’s audiences and their visitors’ usage patterns. We use aggregated information to improve our content, operate our services, and to better understand our audience as we develop new products and services. We may also share aggregated information—which no longer identifies any individuals—with our third-party service providers as well as with potential advertisers, so they can better understand and/or market to our audience.
Third-Party Data Sharing and Disclosure
Business Negotiations. We may contemplate, for strategic or other reasons, selling, buying, merging, or otherwise reorganizing our businesses. In negotiating with a third party about entering into such an arrangement, we may need to disclose your PII. In such cases, we will take reasonable measures to protect the PII we disclose, for example, by requiring a prospective partner or purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the information.
Business Transfers. We may transfer the information you submit on or through the Site or Services, including PII, to a partner or buyer or other successor in the event of a merger, divestiture, transfer of control, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PII held by STERLING, a subsidiary, or an affiliated company about our Site’s and Service’s users is among the assets transferred.
Vendors. We may from time to time retain third-party vendors in order to help us manage the Site and Services and allow us to better serve our visitors and customers. These may include third-party vendors we engage to analyze the information we collect for marketing or similar purposes.
We may also share information, including PII, to third-party vendors to help us provide the Services. For example, we may use a cloud-service provider to host information we collect or other aspects of our Services. Such vendors have access to PII for a limited purpose and for a limited period of time.
We do not disclosure PII to third parties for their own direct marketing purposes.
Links to Third-Party Websites
In General. We respect your right to make choices about the ways your PII is collected and used. For example, we will include instructions to unsubscribe from communications in each electronic newsletter or promotional email we send you.
Unsubscribe from Newsletters or Promotional Communications. We want to provide you information that is valuable to you. If at any time you wish to be taken off our mailing lists, please follow the unsubscribe instructions included in our communications to you or contact us by email at [email protected] or by mail at the address listed below. Please provide your full name, postal address and email address so that we can find you on our mailing lists. Once we have the information we need, we will remove you from our mailing lists as you have requested. Please give us a reasonable amount of time to honor your request.
Opt-Out Links. We do not control how third parties use your information, but you can opt out of certain third-party activities at the links below.
To opt out of Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.
To opt out of certain ad functions, please visit: https://youradchoices.com/control.
Do Not Track Mechanisms. Because of the changing state of technology and indecision within the industry regarding the meaning of Do Not Track signals, we currently do not make any guarantee that we will honor Do Not Track signals.
Our Site and Services are not intended for individuals under the age of 18. Children under 18 years old may not use the Site or Services or access their content without the written permission of a parent or guardian. If you believe that a child under the age of 18 has submitted information on or through the Site or Services without the consent and supervision of a parent or guardian, please contact us as indicated below.
If you have any questions regarding this Policy, please contact us via email at [email protected], by phone at (312) 346-9600 or at the following address:
Sterling Trading Tech
425 Financial Place
Chicago, Illinois 60605
Note: The following section applies to residents of California only.
This section of the Policy, specific to California residents (“California Privacy Rights”) supplements the information contained in Policy above. STERLING has adopted these California Privacy Rights in accordance with the notice requirements under the California Consumer Privacy Act and its associated regulations (“CCPA”), and any terms defined in the CCPA have the same meaning when used in these California Privacy Rights.
These California Privacy Rights apply only to California residents and describe how we collect, use, and share information that relates to you, including through interactions you may have with us outside of our website or a mobile application. For example, when you call our customer service number.
Definitions Specific to this these California Privacy Rights
The CCPA includes definitions for terms specific to these California Privacy Rights that do not apply to the broader Policy, including the following terms:
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include publicly available information obtained from government records, deidentified or aggregated consumer information that cannot be reconstructed to identify you, or certain information governed by existing federal laws.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by us to another business or a third party for monetary or other valuable consideration.
“Service Provider” means for-profit entity that processes information on our behalf and to which we disclose Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity, other than a Service Provider, that collects Personal Information on our behalf or receives it from us.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we collect; examples of the type of Personal Information in each category; the types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and all types of third parties with whom that category of Personal Information is shared. As this chart shows, we disclose certain Personal Information to Service Providers and Third Parties for business and commercial purposes. We also sell certain Personal Information to Third Parties. We do not sell the personal information of minors under 18 years old without affirmative authorization. This information covers the past 12 months.
|Categories of Personal Information||Description or Examples||Sources of Personal Information||Business Purpose(s) for Collection||Third-Party and Service-Provider Recipient(s) of Personal Information|
|Unique identifiers||Name, address, telephone email, account name, online identifier, IP address||From you: When you submit information through the Site or request information about our products and services.||To register you for our Services.
To contact you with relevant information about your inquiry
|Marketing service providers|
|Purchase history||Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||From you: When you purchase a subscription through the Site or Services.||For customer relationship management.
To maintain a record of your purchases and registrations.
|Third-party payment processor acting as a Service Provider.|
|Internet activity||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement||From you: When you use our Site and Services.
From third-party analytics providers: For example, we use Google Analytics to better understand how users interact with our website.
|To improve our Site and Services.
To enable certain website functions.
To inform our marketing and communication efforts.
|IT service providers;
|Geolocation data||Geolocation data||From third-party analytics providers.||To inform our marketing and communication efforts.||NA|
|Inferences||Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||From third-party analytics service providers.||To improve our services and our website.
To improve the content of our marketing and communication efforts.
|Third-party email marketing service provider.|
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
Access to Your Personal Information
Categories of Personal Information Collected: If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of sources from which Personal Information was collected; (3) the business or commercial purpose for which Personal Information was collected, and if sold, the business purpose for such sale; (4) the categories of Personal Information we sold or disclosed; and (5) the categories of third parties with which we shared Personal Information, email [email protected] or call (312) 346-9600. If you submit a request via email, please include “CCPA Request” in the subject line, include the email address and date of birth of the camper associated with the information you are requesting, and that the request is a “request to access categories of personal information.” If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Specific Pieces of Personal Information: If you would like to request the specific pieces of Personal Information we collected about you, email [email protected] or call (312) 346-9600. If you submit a request via email, please include “CCPA Request” in the subject line, include the email address and date of birth of the camper associated with the information you are requesting, and that the request is a “request to access specific pieces of personal information.” If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Deletion of Your Personal Information
You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, email [email protected] or call (312) 346-9600. If you submit a request via email, please include “CCPA Request” in the subject line, include the email address and date of birth of the camper associated with the information you are requesting be deleted, and that the request is a “request to delete.” If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Right to Opt Out
You have the right to request that we not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.
If you would like to request that we not sell your Personal Information pursuant to the requirements of the CCPA, email [email protected] or call call (312) 346-9600. If you submit a request via email, please include “CCPA Request” in the subject line, include the email address and date of birth of the camper associated with the information you are requesting be deleted, and that the request is a “request to opt-out.” If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
If you use an authorized agent (see the “Authorized Agents” section below) to submit your request to opt-out, we will request that the agent provide us with proof that the agent has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information again.
Before responding to your request, we will verify your request by comparing the information you provide with the request to information we hold in our systems. In some cases, we may request additional information to confirm that we have identified the correct records in our systems. Subject to certain exceptions that may apply in the CCPA, if we are able to verify your request, we will accommodate your request. If we are unable to accommodate your request fully, we will provide you additional information about the reasons that we could not fully comply with your request. After you submit a request, to ensure the privacy and security of our customers’ information, we may reach out to you for additional information if it is needed to verify your identity.
You may designate an authorized agent to exercise your rights under the CCPA on your behalf.
Pursuant to the CCPA:
- Only an individual with power of attorney, or a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
- We may require that you or the authorized agent do the following:
- Provide proof of your signed written permission for the authorized agent to submit a request on your behalf – We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
- Verify your identity with us directly – This does not apply if you have provided a valid power of attorney to the authorized agent.
Personal Information of Minors
We do not knowingly sell the Personal Information of minors under the age of 18. If you believe we inadvertently collected information from a child under the age of 18, please send an email to [email protected] so that we may remove it from our records.
If you would like additional information regarding these California Privacy Rights, please email us at [email protected] or call (312) 346-9600.
Additional California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected] with the subject “Shine the Light Request.”
Note: The following section applies to residents of the European Economic Area only.
For the purposes of this section, PII is equivalent to personal data, as it is defined in the EU’s General Data Protection Regulation (Regulation (EU) 2016/679).
Processing in the United States
This Site and the Services are operated by STERLING in the United States and any PII submitted through the Site or Services will result in the collection and processing of such information in the United States. As a result, if you are visiting the Site or Services from the European Economic Area (or any other country other than the United States), your PII will cross an international boundary. The level of protection for your PII in the United States may not be the same as the level of protection in your country.
Lawfulness of Processing
We collect, use, and otherwise process your PII based on the following:
- Based on your consent: In some cases, at the point at which you provide PII, we may ask you for your consent to collect and process your PII. If you choose to provide us with your consent, you may later withdraw your consent (or opt-out) by contacting us as described below. Please note that if you withdraw your consent it will not affect any processing of PII that has already occurred. Where we process your PII based on consent, we may provide more detailed information to you at the time when we obtain your consent.
- Compliance with applicable laws or performance of a contract: In specific circumstances, we may need to process your PII to comply with a relevant law/regulation or to fulfill our obligations under a contract to which you are subject. Where we process your PII to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations. Where we are processing your PII to fulfill our obligations under a contract to which you are a party (e.g., to provide you with our products and services), you might not be able to object to this processing, or if you do choose to opt-out or object to our processing, it may impact our ability to perform a contractual obligation that you are owed.
- Our legitimate interest: We may process your PII based on our legitimate interests in communicating with you and managing our interactions with you regarding our products and services. In addition to other rights you may have as described below, you have the right to object to such processing of your PII. You can register your objection by contacting us as described below.
Your Data Protection Rights
We comply with applicable data protection laws and value your right to privacy. In furtherance of our obligations to you that flow from our data collection practices, if you are resident in the European Economic Area you are entitled to the following rights:
- The right to access – You have the right to request copies of your PII. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your PII, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your PII, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your PII, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- Right to submit complaints to Supervisory Authorities – You have the right to lodge a complaint with an applicable data protection authority. If you reside in Europe, you have the right to lodge such a compliant in the European country of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your PII infringes applicable EU data protection laws. A list of all European supervisory authorities and their respective contact information is available here.
If you make a request, we will respond within one month of receiving your request. If you would like to exercise any of these rights, please contact us at [email protected] or (312) 346-9600.