Your Privacy Is Important To Sterling Merchant Finance Ltd

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Sterling Merchant Finance Ltd may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately. This Policy describes the types of personal information we may collect about you, the purposes for which we use the information (including those with whom we may share it), and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term "Sterling Merchant Finance Ltd" refers to The Sterling Merchant Finance Ltd and its affiliates worldwide.

The Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Sterling Merchant Finance Ltd during the course of your relationship with us. We may also collect information about your transactions and experiences with Sterling Merchant Finance Ltd relating to the products and services Sterling Merchant Finance Ltd provides. In addition, depending on the products or services you require, Sterling Merchant Finance Ltd may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis but it may be used for compliance or security purposes.

The Information We Have About You

If you deal with Sterling Merchant Finance Ltd in your individual capacity (e.g., as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:

• Your name, address and other contact details;
• Extensive financial information, including investment experience and objectives, risk tolerance, and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

• Your name and contact details;
• Your role/position/title and area of responsibility; and
• Certain identifying information (e.g., passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.
• Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:
• Administer, operate, facilitate and manage your relationship and/or account with Sterling Merchant Finance Ltd. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
• Provide you with information (such as investment research), recommendations or advice concerning products and services offered by Sterling Merchant Finance Ltd; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Sterling Merchant Finance Ltd ends, Sterling Merchant Finance Ltd will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information Within Sterling Merchant Finance Ltd

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within Sterling Merchant Finance Ltd may be given access to your personal information. For example, one Sterling Merchant Finance Ltd entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts or as part of its arranging for the performance of specialized services such as U.S. and international brokerage, asset management, and advisory and trust services. When so sharing your personal information we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Sterling Merchant Finance Ltd is provided below under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties

Sterling Merchant Finance Ltd does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Sterling Merchant Finance Ltd, including those that provide professional, legal, or accounting advice to Sterling Merchant Finance Ltd. Non-affiliated companies that assist Sterling Merchant Finance Ltd in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Sterling Merchant Finance Ltd dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.

You should know that Sterling Merchant Finance Ltd will not sell your personal information.

Information Security: How We Protect Your Privacy

Sterling Merchant Finance Ltd is committed to implementing the highest standards of information security to protect the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Sterling Merchant Finance Ltd employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

• A dedicated group - the Information Security Department - that designs, implements, and provides oversight to our information security program;
• The use of specialized technology such as firewalls;
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as on-going scanning for publicly-known vulnerabilities in the technology;
• Internal and external reviews of our Internet sites and services;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate and authorize access to various systems or sites;
• Protecting non-public communications through encryption or other means; and
• Providing Sterling Merchant Finance Ltd personnel with security-related training and continually updating our security practices in light of new risks and developments in technology.

Privacy and The Internet

The following additional information will be of interest to you if you access Sterling Merchant Finance Ltd products or services through one or more Sterling Merchant Finance Ltd Web sites:

• Users of private Sterling Merchant Finance Ltd Web sites are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password, or with an RSA SecurID* Card and a Personal Identification Number ("PIN").
• The private Sterling Merchant Finance Ltd Web sites are built upon a secure infrastructure with multiple layers of protection, including measures ranging from proper physical security of our machines to system intrusion detection capabilities. Within such private sites, Sterling Merchant Finance Ltd uses industry standard encryption technologies to protect your information from external compromise.
• Security is a cooperative effort between Sterling Merchant Finance Ltd and the users of the Sterling Merchant Finance Ltd Web sites. Please remember that your password, RSA SecurID Card and PIN are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
• "Cookies" are small text files consisting of encrypted information assigned to a computer's browser. Sterling Merchant Finance Ltd may use cookies for administrative purposes, such as to maintain security on the site, or to identify you so that you do not have to input your password multiple times as you navigate a Sterling Merchant Finance Ltd Web site.
• "Clickstream" or similar data (e.g., information regarding which of our Web pages you access, the frequency of such access, etc.) may be collected and shared internally in order to assess the usage, value and performance of our on-line products and services.

Other Privacy Policies or Statements; Changes to Policy This Policy provides a general statement of the ways in which Sterling Merchant Finance Ltd protects your personal data. You may, however, in connection with specific products or services offered by Sterling Merchant Finance Ltd, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of client personal information. The revised Policy will be effective immediately upon posting to our Web site. This version of the Policy is effective November 18, 2003.

You are entitled to access any personal data about you held by Sterling Merchant Finance Ltd by sending a written request to the applicable individual identified below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal data. We will process your request within the time provided by applicable law. You are also entitled to have Sterling Merchant Finance Ltd modify or delete any information that you believe is incorrect or out of date.

Sterling Merchant Finance Ltd may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices please contact::

Sterling Merchant Finance Ltd
One Lafayette Center, North Tower
1120 20th Street, NW
7th Floor
Washington, DC 20036