Privacy Policy

This Privacy Policy explains how Sterling Holdings ("Sterling", "we", "us"), registered at 515 Madison Avenue, Suite 1118, New York, NY 10022, USA, collects and uses personal information when you use our website and platform.

For data protection purposes, we are the controller of your personal information.

• Account details: your name, email address, password (stored only as a secure hash), phone number and country of residence.
• Identity verification: images of your identity document, its number, your date of birth, your residential address and, where we ask for one, a photo of you.
• Financial activity: your deposits, participations, yield, withdrawals, wallet addresses and transaction hashes.
• Technical information: your IP address, device and browser details, log-in times and approximate location.
• Enquiries: what you tell us through our contact form or by email.
• Referrals: who referred you, and whom you referred.

• To open and run your account.
• To verify your identity and meet our legal obligations, including anti-money-laundering checks.
• To process deposits, participations and withdrawals, and keep an accurate record of your balance.
• To send service emails, such as deposit confirmations and maturity notices.
• To keep your account secure, including spotting unusual log-ins.
• To reply to your enquiries.
• To improve our website using privacy-friendly analytics.

Where [data protection law] requires a legal basis, we rely on the performance of our contract with you, compliance with our legal obligations, our legitimate interest in running a secure and reliable service, and your consent where we ask for it. You can withdraw consent at any time.

We do not sell your personal information. We share it only with:

• Service providers who host our platform, send our emails and provide analytics, under contracts that protect your information.
• Identity verification and compliance partners, where we use them.
• Our professional advisers.
• Authorities, where the law requires it.

Our service providers may process information outside [jurisdiction]. Where they do, we use the safeguards required by [data protection law].

We keep records of deposits, participations, withdrawals and our audit logs for at least 7 years, or longer where the law requires. We keep identity documents for [5] years after your account closes, and enquiries for up to 24 months. After that we delete or anonymise the information.

Identity documents are stored privately and encrypted, only authorised staff can open them, and every access is logged. We use HTTPS throughout, store passwords only as secure hashes, require two-factor authentication for staff and offer it to every customer.

We use essential cookies to keep you logged in and your session secure. Our analytics are privacy-friendly and do not follow you across other websites. If we ever introduce non-essential cookies, we will ask for your consent first.

Depending on where you live, you may have the right to access, correct or delete your information, to object to or restrict how we use it, to receive a copy in a portable format, and to withdraw consent.

Some records, such as your transaction history, must be kept to meet legal obligations even if you ask us to delete them. To exercise your rights, email [privacy contact email]. You can also complain to [supervisory authority].

We will post any changes on this page with a new version number and date. If a change is significant, we will also tell you by email or in your dashboard.

Sterling Holdings, 515 Madison Avenue, Suite 1118, New York, NY 10022, USA. Email: sterlingholdingscapital@gmail.com.