Privacy Policy and Disclosure

The directors, management and staff of Sterling Bank are concerned about and respect the privacy of our customers’ personal financial information. We understand that our customers furnish sensitive information to the bank in the course of daily business, and the bank is committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.

The bank will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers. The following privacy policy and disclosure outlines our bank’s practice regarding personally identifiable financial information for consumers and those consumers who become our customers.

Types of Information the Bank Collects

At Sterling Bank we collect nonpublic personal information from many sources. The bank collects nonpublic personal information directly from consumers on various applications and forms, for example, loan applications, deposit account applications, and requests for information about accounts or products and services. The Bank collects information we may receive from a consumer-reporting agency. The bank also collects information as a result of transactions between the bank and our customers and as a result of providing a product or service to our customers. This includes transaction information from checks, debit cards, credit cards, automated teller machine (ATM) cards, and electronic transfers (e.g., home banking or automated clearing house (ACH) transactions). Nonpublic personal information does not include that which the bank obtains from government records, widely distributed media, or government-mandated disclosures.

Types Of Information The Bank Discloses

The bank does not now, nor does it intend in the future, to disclose any personal financial information to any nonaffiliated or affiliated third party. By law the bank may disclose certain personally identifiable information without allowing consumers the right to opt out of the bank’s sharing agreements in the following circumstances:

• To companies who perform transaction processing for the bank in the following circumstances:
  
• If the transactions, service, or product is requested by the consumer
  
• To maintain or service a consumer’s account as part of a private label credit card or other loan extension program
  
• In connection with a securitization, secondary market sale (including servicing rights), or similar transaction related to a consumer
  
• To disclose information necessary to enforce the bank’s legal or contractual rights or the rights of any other person who is engaged in the financial transaction
  
• To disclose information required in the ordinary course of banking business, such as in the settlement of claims or benefits, the confirmation of information to the consumer or the consumer’s agent, and the billing, processing, or clearing of items in the normal course of business
  
• To provide information to insurance rate advisory organizations, guaranty funds, or agencies, agencies that are rating the bank, persons that are assessing the bank’s compliance with industry standards, and the bank’s attorneys, accountants, and auditors.
  
• To the extent permissible under the Right to Financial Privacy Act
  
• To a consumer reporting agency under the Fair Credit Reporting Act
  
• To comply with federal, state, or local laws, rules, and other applicable legal requirements
  

Authorized Sharing With Outside Marketing Services

We may disclose the following information to companies that perform marketing services on our behalf:

Nonpublic personal information we receive from you on an application or other forms, such as Name, Address, Social Security Number, Assets, or Income.

Nonpublic personal information about your transactions with us, such as Account Balance, Account Activity, Types of Accounts, Credit card usage, Payment history, Deposit History, Parties to a transaction.

The types of businesses with whom we may disclose nonpublic personal information for outside marketing purposes are Service providers that perform marketing services for us, Telemarketing companies, and Direct sales companies.

Authorized Sharing – Joint Marketing

We may disclose the following information to other financial institutions with which we have joint marketing agreements:

• Nonpublic personal information we receive from you on an application or other forms, such as Name, Address, Social Security Number, Account Balance, Assets, and Income. 
  
• Nonpublic personal information about your transactions with us, such as Account balance, Account activity, Types of accounts, Payment history, Deposit history, or Parties to a transaction.
  
• Federal law allows us to disclose the information listed above with companies that perform marketing services on our behalf. You do not have a right to opt out of the disclosure of this information. We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law.

Safeguarding Customer Information

At Sterling Bank we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. We also maintain physical, electronic, and procedural safeguards that comply with Federal standards to guard your nonpublic personal information. For example, only employees who work in the loan origination or loan operations areas can access information in loan files.

All employees are trained at least annually regarding the importance of safeguarding customer information. The Bank will take disciplinary action against any employee who violates the bank’s privacy policy and procedures.

If we change our policy or practice by, for example, adding a category of information that will be disclosed to a third party, the bank will notify existing customers and give them an appropriate time period to opt out of the disclosure.

Contact Us: 
Sterling Bank
P. O. Box 20509
West Palm Beach, FL 33416-0509
(561) 968-1000