Privacy Policy

Privacy Notice and Notice of Information Practices

Sterling Resources Insurance Agency, Inc.

Sterling Resources International of Bermuda

Sterling Resources Ltd.

Sterling Resources Insurance Agency, Inc. and its affiliates Sterling Resources International of Bermuda and Sterling Resources Ltd. (collectively "Sterling") respect you and your right to privacy. We want you to know about our policies and procedures for protecting the privacy of your nonpublic personal and financial information that we receive, and your rights regarding such information.

This notice explains our policies and practices as of July 1, 2001, regarding the nonpublic personal and financial information about our clients contained in our records in accordance with the Gramm-Leach-Bliley Act ("GLBA") and the Privacy of Consumer Financial Regulation promulgated by the Federal Trade Commission pursuant to GLBA. We reserve the right to amend, modify or supplement our privacy policy at any time in accordance with applicable law. If we make changes to our privacy policy, we will provide you with a copy of a revised Notice as required by applicable law. This Notice applies to individuals who are current and former clients to whom we provide or have provided life insurance planning services or whom we have assisted with the purchase of life insurance in our capacity as a life insurance agent, broker or consultant.

This Notice and Privacy Policy described herein do not apply to your relationships with other financial services providers that are not affiliated with Sterling, such as your accountant, financial advisors, investment advisors or any lawyers or law firms that may represent you. Their privacy policies and information practices govern how they collect, use and disclose information about you.

1. What kind of information we collect about you

We collect non-public information about you from the following sources:

2. What we do with the information we collect about you

We may disclose information about you to our affiliates and use that information for purposes related to our providing services to you. In addition, we may disclose information about you to an insurance carrier for purposes of assisting you in the procurement of life insurance contracts. Generally, we will not disclose the nonpublic information about you in our records to any other organization not affiliated with Sterling without your prior authorization. However, as required by law, we may disclose certain information about you in response to a subpoena or other discovery request made in a litigation matter.

3. Who has access to your information in our records

We maintain appropriate physical, electronic and procedural safeguards to protect against unauthorized access to your nonpublic personal and financial information contained in our records. Access to such information is restricted to individuals who need to know the information to service your account or to provide products or services to you. We will educate our employees about the terms of this Notice and the importance of confidentiality and consumer privacy. Each employee of Sterling is required to sign and comply with a confidentiality and nondisclosure agreement.