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July 4, 2008
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    STERLING BANK INTERNET PRIVACY STATEMENT
    Sterling Bank respects your privacy. Through our web site, we strive to provide valuable information to you about how we may serve you. Whether you are a valued customer or someone shopping for new banking services, we hope our site answers your questions about our products and services, our convenient locations, and hours of operations.

    I. INFORMATION WE COLLECT FROM E-MAILS
    Our web site does not require you to disclose any personal information. If however, you choose to contact us via e-mail, please keep in mind that your e-mail address, and any other information your e-mail header displays, such as your name or organization, will be revealed to us in the e-mail. We pledge, however, that when you communicate with us via e-mail, we will use your e-mail information only for the specific purpose of responding to your comments or questions. Your e-mail address will not be sold, nor will it be shared with others outside the Bank unless we are compelled to do so by law.

    II. FOR MORE INFORMATION
    If you have specific questions or concerns about Sterling Bank’s Information Privacy Policy, please call (856) 273-5900 or write to us at Sterling Bank, Attention: Privacy Act Officer, 3100 Route 38 Mount Laurel, NJ 08054.
    Sterling Bank reserves the right to change this policy at any time by posting a new privacy policy.

    III. USE, COLLECTION AND RETENTION OF CUSTOMER INFORMATION
    Sterling Bank identifies and tracks the single, previous web site address visitors have come from when accessing our site. This is a standard industry practice used to determine how people navigate to our site. When a member accesses the sterlingnj.com web servers, we store a cookie - a tiny piece of information - on the member's computer. This file is a technical requirement that establishes and maintains a secure session so members can request information and conduct business transactions. The cookie contains no confidential or personal information and is not used to track member activity after leaving sterlingnj.com.

    PRIVACY POLICY STATEMENT
    Sterling’s relationship with its customers is uniquely personal. That is why we work diligently to safeguard your privacy. The information that you provide us is kept in the strictest of confidence. We have no intention of selling personal information about our customers to third-party businesses. We are proud to make that commitment to you, because your trust is the foundation of our business.

    The following privacy policy explains how we use and protect the information about our customers. We ask that you read it carefully.

    STERLING BANK's PRIVACY POLICY

    RECOGNITION OF CUSTOMER’S EXPECTATION OF PRIVACY
    Customers of the Bank are entitled to the assurance that the information concerning their financial circumstances and personal lives, which the bank has obtained through various means, will be treated with confidentiality and respect. Certain expectations of privacy also contain legal rights of customers, which are either granted or affirmed through various federal and state laws and regulations. All employees are directed by this policy to communicate to customers the Bank’s commitment to preserving the privacy of their information. The Bank will post a notice, in all banking offices, which contains an abbreviated version of this policy. That notice is designed to be both a posted notice and a direct disclosure to customers under circumstances described later in this policy.

    USE, COLLECTION AND RETENTION OF CONSUMER INFORMATION
    It is the policy and practice of the Bank to limit collection, retention and utilization of information about consumers and customers (both individual and corporate) to instances where the Bank reasonably believes the gathering of such information would be useful and allowed by law to administer the bank’s business, to provide products, services or opportunities to its customers and comply with legal and regulatory requirements. These practices require certain administrative actions by employees in order to maintain customer privacy.

    MAINTENANCE OF ACCURATE INFORMATION
    Executive management is directed to establish procedures to establish that, to the extent practicable, all customer financial information is accurate, current and complete in accordance with reasonable commercial standards. The Bank will respond promptly and affirmatively to any legitimate customer request to correct inaccurate information, including forwarding of corrected information to any third party that had received the inaccurate information. In this regard, customers concerned about or questioning personal or financial data should be directed to the appropriate area, where investigation and correction, if required, can be completed on a timely basis. The Bank will further undertake to record that, such corrective action was requested by the customer, and will follow up with any third party to determine that they have processed the correction. Regulatory requirements must be observed for error resolution under Regulation E (Electronic Funds Transfers), Regulation Z (Fair Credit Billing), the fair Credit Reporting act, and other applicable laws and regulations.

    LIMITATION ON EMPLOYEE ACCESS
    Executive management will take reasonable steps such that only authorized employees and those with a legitimate business reason for knowing personally identifiable customer information shall have access to such information. To the extent practicable, access will be limited by computer access codes and limited access to areas in which sensitive customer information is retained. There should be no discussion of customer-sensitive issues among employees unless such is needed to perform the business function. Employees will be informed at the time of their initial employment of this standard and periodically reminded of these standards during training sessions at least once during each calendar year. Willful violation of this element of this policy will result in disciplinary action against the offending individual. See the following Protection of Information section for security standards for sharing or giving customer information.

    PROTECTION OF INFORMATION
    The Bank will maintain reasonable security standards and procedures to prevent unauthorized access to customer information. Specific security procedures regarding certain access codes, passwords, etc. are adhered to by each department regarding their operational procedures. Such procedures should provide protection against access by unauthorized persons. Such other persons include but are not limited to; all non-employees with otherwise legitimate reasons for being on bank premises and all intruders on bank premises.

    GENERAL RESTRICTION ON THE DISCLOSURE OF CUSTOMER INFORMATION
    The Bank will not, except in cases allowed under the law, reveal specific information about customer accounts or other nonpublic personal information to any non affiliated third parties unless the customer has be provided the required privacy disclosures and is given the opportunity to decline or “opt out”.

    BUSINESS RELATIONSHIP WITH THIRD PARTIES
    If the Bank is requested to provide personally identifiable information to a third party and that request is in all respects consistent with other elements of this policy, the Bank will accede to the request only if the third party agrees to adhere to similar privacy principles, no less stringent than set forth in this policy, that provide for keeping such information confidential.

    INFORMATION SHARING WITH THIRD PARTY VENDORS FALLS INTO THE FOLLOWING CATEGORIES:

    Contract
    Sterling Bank may share certain customer information with third party vendors who are under contract to provide operational support (for credit reporting agencies, search companies and title agencies), supply products and services and promote products and services on the Bank’s behalf. These companies are not permitted to use our customer information for purposes other than to provide the service under contract. Each contract with a third party must contain language agreeing to treat all customer information confidentially.

    Non-Contract
    All new vendors or agents who are not under contact, but who are provided with either customer information or with inside-business information in order to perform their business for the bank (e.g., attorneys, appraisers, consultants), must sign the bank’s Corporate Non-Disclosure and Confidentiality Agreement. This agreement will be maintained by the Compliance Officer.

    DISCLOSURE OF PRIVACY PRINCIPLES TO CUSTOMERS AND CONSUMERS
    Sterling Bank’s privacy notice is provided to all customers initially and then annually, thereafter.

     
         
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