privacy policy

Sterling Cooper, Inc. ("Sterling Cooper") recognizes the importance of protecting the privacy of certain Information collected about the users and visitors ("user," "you" or "your") of Sterling Cooper's Web site ("Web Site"). The following privacy and information practices policy discloses and describes what Information Sterling Cooper may gather about you, how Sterling Cooper may use such Information, and how you can correct or change such Information ("Privacy Policy"). This Privacy Policy is designed to give you an understanding about how Sterling Cooper collects your Information and the uses Sterling Cooper may make of such Information during the course of Sterling Cooper's business and in providing you with access to the information, products and services that may be available at this Web Site.

You should print a copy of this Privacy Policy for your records. Please note, however, that Sterling Cooper may update and amend this Privacy Policy from time to time as Sterling Cooper deems necessary in its sole discretion. Certain capitalized terms used in this Privacy Policy may be defined in Sterling Cooper's separate Web Site Terms of Use.


Sterling Cooper's purpose in establishing this Privacy Policy is to balance its legitimate business interests in collecting and using its users' Information with its users' reasonable expectations of privacy. Sterling Cooper's intent is to provide to you certain offers, information, services and discounts that it believes are relevant to your interests. Sterling Cooper believes that its users will benefit from promotional activity based on certain information employed to market goods and services offered by and through its businesses.


How Does Sterling Cooper Collect Information?


Optional Registration:

Sterling Cooper collects Information by specifically requesting it from you. Generally this occurs when you register at the Web Site or request information or a service. You may elect, at your sole option, whether to provide the requested Information, although you may not be able to use or gain access to certain portions or features of this Web Site if you elect not to provide such Information. Usually, Sterling Cooper and/or its business partners use your Information to operate the Web Site and to deliver information and services to you. Sterling Cooper also uses your Information to inform you about other products and/or services available from Sterling Cooper, its affiliated or related entities, and/or its Providers.


Information from Third Party Sources:

Sterling Cooper may collect information about you from third party sources to supplement the Information otherwise provided by you at this Web Site. This supplemental information allows Sterling Cooper to verify Information that you have provided to Sterling Cooper and to enhance Sterling Cooper's ability to provide you with information about its businesses, products and services, as further described in Sterling Cooper's Web Site Terms. Sterling Cooper's agreements with these third party sources typically limit how Sterling Cooper may use this supplemental information.


With Whom Does Sterling Cooper Share Information?

As a general rule, Sterling Cooper will not share with or disclose to any third parties any specific personally identifiable information about you that you may submit or provide to Sterling Cooper via this Web Site ("Personal Information"), in a manner that connects you with the Personal Information, except (a) as otherwise described in this Privacy Policy, (b) when Sterling Cooper has your permission, or (c) under special circumstances, such as when Sterling Cooper believes in good faith that the law requires such disclosure or under the circumstances described below. The following describes some of the ways that your Personal Information may be disclosed:

Other: Sterling Cooper may also disclose account information in special cases when it has reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Web Site Terms or this Privacy Policy, or may be causing injury to or interference (either intentionally or unintentionally) with any of Sterling Cooper's rights or property, other users, or anyone else. Sterling Cooper may disclose or access account information when it believes in good faith that the law requires it (and/or if compelled to do so by law enforcement or government agencies, or by other legal action), and for administrative and other purposes that it deems necessary to maintain, service, and/or improve this Web Site or its products and services.

Careers with Sterling Cooper: This Web Site may provide you the ability to search for job postings and/or submit applications for potential employment opportunities. Sterling Cooper may use third parties to collect and/or host these types of services or related information. If a third party service provider is used for these purposes, the third party provider is prohibited under agreement from using any Personal Information that you may submit in conjunction with these services for any purpose other than to collect and store such Personal Information on Sterling Cooper's behalf. The Personal Information that you submit for these purposes will not be used for any purpose other than to allow you to search for job postings, submit applications, or determine your qualifications for employment with Sterling Cooper or its affiliated or related entities.

Investor Center: This Web Site may allow you to subscribe to investor newsletters, press releases, e-mail alerts, and other related communications. The Personal Information that you may provide in conjunction with these subscription services or offerings will be used only for the purpose of providing you with such services or for responding to your subscription requests.

Children: This Web Site is not intended for use by children. Sterling Cooper does not knowingly solicit or collect Personal Information from children under the age of 18. If you are under the age of 18, you must obtain the consent of your parent or guardian to use this Web Site.


Opting Out; How Can You Control the Use of Information?

In the event that you decide that you want to opt out from Sterling Cooper's use of any Personal Information that you previously provided to (and/or authorized for use by) Sterling Cooper, or if any of your Personal Information (such as your zip code or e-mail address) changes, Sterling Cooper will use reasonable efforts to provide you with a way to correct, update or remove such Personal Information. Sterling Cooper makes repeated efforts to verify the accuracy of your Personal Information and to correct and update its databases based on the information available to Sterling Cooper. In the event that you believe that any Personal Information held by Sterling Cooper is inaccurate or outdated, Sterling Cooper, upon notification and sufficient time for verification, will take all reasonable steps to correct any inaccuracy or update outdated Personal Information of which it is made aware. Sterling Cooper also gives you the opportunity to control or opt out from the communications that Sterling Cooper directs to you. If you wish to update or change your Personal Information or opt out from any use or communication described in this Privacy Policy for any reason, you may notify Sterling Cooper of such update, change or opt out by contacting:


Is Your Information Secure?

The security of all Information associated with users of this Web Site is an important concern to Sterling Cooper. Sterling Cooper exercises reasonable care in providing secure transmission of your Information from your computer to Sterling Cooper's servers and databases. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while Sterling Cooper strives to protect your Information, Sterling Cooper cannot ensure or warrant the security of any Information you transmit to Sterling Cooper, and you do so at your own risk. Once you complete the transmission of, and Sterling Cooper receives, your Information, Sterling Cooper uses industry standard efforts and practices to safeguard the confidentiality of your Personal Information, and uses commercially reasonable efforts to collect and secure such Personal Information consistent with all applicable laws and regulations. Sterling Cooper takes commercially reasonable efforts to use a variety of different security measures (such as encryption, digital certificates, firewalls and Secure Socket Layers) designed to protect Personal Information from access by unauthorized users both inside and outside of Sterling Cooper, and to protect against the unauthorized or improper alteration or destruction of such Personal Information. Sterling Cooper's communication system, software and database practices have been designed to aid in supporting authenticity, integrity and confidentiality. However, as described above, "perfect security" does not exist on the Internet and, despite these reasonable efforts by Sterling Cooper to maintain data and Information security, Sterling Cooper cannot guarantee the security of data or Information.



By using this Web Site, you signify your agreement to the terms of Sterling Cooper's Internet Privacy Policy. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THIS WEB SITE. Your continued use of Sterling Cooper's Web Site following the posting of any changes or updates to the terms of this Privacy Policy will signify your acceptance of those changes and updates.

Effective date: This policy was last updated on November 18, 2008.