At The St. Louis Trust Company we believe that it is essential to protect the privacy of client information, including a client’s personal information.
Information We Collect and How We Use It
We primarily collect and process information, including personal information, that you provide to us as part of the Services. Personal information means information that can directly or indirectly identify you or other individuals. Personal information typically includes information such as your name, social security number, address, email address, and telephone number, but can also include other information such as IP address, information about health, or information about your lifestyle or preferences such as your hobbies and interests. As applicable, references to “personal information” shall be deemed to include “personal information” as defined in the California Consumer Privacy Act of 2018 (“CCPA”), and any other similar term used in applicable data protection law.
In the course of our business relationship, we obtain personal information about clients in the following manners:
- directly from clients in the course of meetings or other communications (such as name, signature, social security number, alias, postal address, telephone number, employment history, income, assets, beneficiaries, investment objectives, bank account number, credit card number, debit card number, account activity, loan history, any other financial information, or any other investment-related information or documents, driver’s license number, passport number, state identification card number, date of birth and/or age, unique personal identifier, online identifier IP address, email address, or other similar identifiers);
- automatically when clients interact with and navigate the Website or the Portal (such as information about the type of browser you use, details of the web pages you have viewed, your IP and device address, your Cookie ID, hyperlinks that you have clicked, the websites you visited before arriving at the Website, and information collected by cookies or similar tracking devices);
- from clients on applications, surveys or other forms (such as name, signature, alias, postal address, email address, telephone number, social security number, employment history, income, assets, beneficiaries and investment objectives, bank account number, credit card number, debit card number, account activity, loan history, any other financial information, or any other investment-related information or documents);
- through client transactions with other financial institutions (such as account activity, loan history and transaction information from other financial advisers and banks with whom clients work or with whom we engage); and
- from outside agencies or other advisers or investment managers with whom clients work or with whom we engage (such as Services history and performance detail relating to investments, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
Typically, to use the Website, the Portal or our Services, you will need to provide some personal information. Our Services are designed around user-specific personalization, so not all of the Services require you to provide personal information. For example, if you do not log into the Portal or consent to cookies on our Website then you will not need to provide any personal information on the Website or the Portal. However, if you do not provide personal information, you may not be able to use all of the features of the Website, the Portal or the Services.
We limit personal information collection, use, retention, and disclosure to activities reasonably necessary and proportionate to achieve the provision of the Services to you or another compatible operational or legal purpose.
In particular, we process personal information for the purposes listed below:
- to facilitate and provide you with the Services that you request from us, including to process transactions, service client accounts, determine and fulfill investment objectives, and comply with applicable laws and regulations;
- to respond to your inquiries, comments and other communications and to otherwise communicate with you;
- to allow you to use the Website, the Portal or the Services and to process data about such use;
- to improve the Services and your experience with us, including on our Website or the Portal;
- to provide relevant information to clients and potential clients relating to our Services and industry;
- to develop or operate financial/credit/conduct and risk models, conduct internal analysis of clients, plan strategy and growth, collate reporting and management information to support:
- to facilitate business reporting;
- to conduct back-office operations;
- to produce aggregate analytics and business intelligence;
- to manage of third party relationships;
- to process identifiable data for the purpose of anonymizing/de-identifying/re-identifying it for the purposes of using the anonymized data for other purposes;
- to plan for strategic growth, including management of client, vendor and other relationships, sharing intelligence with internal stakeholders, and planning and allocating resources and budgeting;
- to identify and prevent potential fraudulent acts in connection with the use of our Services, to prevent harm to St. Louis Trust, the Website, the Portal, the Services or to any person or property (e.g., fraud prevention), and/or to bring, prosecute or defend against a claim or potential claim; and
- to fulfill any other purpose for which you provide it or for any other purpose with your consent.
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: when you become a client, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. In addition, we may share this information with a third-party vendor that we use to help us comply with our obligations under federal law.
To the extent legally permitted, we may aggregate, deidentify, or anonymize personal information so it no longer meets the definition of personal information using acceptable methods, and may use such aggregated, deidentified, or anonymized data for other purposes. We will not attempt to or actually re-identify any previously aggregated, deidentified, or anonymized data.
Sharing Personal Information
St. Louis Trust strives to limit sharing of personal information about clients with third parties. However, in order to provide the quality service that our clients know and expect from us, from time to time we may need to share personal information about our clients with third parties. The situations that may require us to share personal information with third parties include the following:
- We may disclose personal information to affiliated and non-affiliated third parties, when required to process transactions or provide information to service client accounts. These third parties may include, but are not limited to, insurance brokers, custodians, money managers, account brokers, accounting or other professional firms involved in tax return preparation or other planning for client purposes. For example, in order to complete various subscription agreements, investment management agreements and other investment related documents on your behalf, we may need to provide copies of estate planning documents such as trusts, partnership agreements or LLC agreements to custodians or investment managers.
- We may disclose personal information to third party consultants, vendors or companies for the purposes of improving or maintaining the functionality and integrity of our computer systems, the Website, the Portal or the Services.
- We may disclose personal information in limited circumstances to third parties where we believe in good faith that disclosure is required or reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request.
In addition to disclosures described above, we may disclose or transfer personal information in connection with, or during negotiations of, any merger, acquisition, spin-off, sale of company assets, product lines or divisions, any financing or any similar transaction, and we may disclose or transfer personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
We educate our employees on the importance of maintaining the confidentiality of client personal information and hold them to strict compliance. We maintain physical, electronic and procedural safeguards that comply with industry standards to guard client personal information. Although we make substantial effort to protect your personal information, the security mechanisms of e-mail and the internet are by their nature limited, and we cannot guarantee the absolute privacy, security or authenticity of electronic transmissions. Any account information you enter on the Portal is password‑protected so that only you can access it. You should not divulge your password or username to anyone.
Links to Other Sites and/or Service Providers
Personal Information Related to Children
We are committed to protecting children’s privacy on the internet, and we do not knowingly collect, use or disclose personal information (including online contact information) from children under the age of 16. The Services provided by St. Louis Trust are not intended for use by children under the age of 16. If you are under 16, do not use or provide any information on or through the Website, the Portal or the Services. If we learn we have collected or received personal data from a child under 16 without verification of parental consent, we will delete that information.
Your Rights to Your Personal Information
Subject to applicable law, clients may remove or revise any of their personal information in our client records at any time by contacting us.
To the extent that certain data protection laws apply, you may have the right to:
- Confirm whether or not we process personal information from you and, where that is the case, access the personal information;
- Rectify inaccurate personal information;
- Delete personal information;
- Restrict the processing of sensitive personal information; and
- Receive the personal information which you have provided to us and transmit those data to another data controller without hindrance.
To the extent applicable, you may exercise any of these rights by contacting us at: firstname.lastname@example.org
We will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law and/or regulation governing the use of the given personal information. Please note that we may require additional information from you in order to honor the request.
You also have the right to lodge your complaints with the applicable legal authorities.
California residents may have additional rights and choices with regard to their personal information. Please see the California Privacy Rights section below for more information.
California Privacy Rights
Do Not Track (DNT) is a privacy preference that users can set in their web browsers. When the Website receives a DNT code, except in the case of certain scenarios where a user actively and knowingly provides personal information (e.g. contact forms), the Website will not track that user’s use, but other websites to which we link, or to which a user visits, may continue to track the users. When the Website receives web requests from a user who enables DNT by actively choosing an opt-out setting in the user’s browser, we will also take reasonable efforts to disable tracking cookies/scripts (e.g. Google Analytics and/or other third party scripts).
We may collect information that constitutes “personal information” under the CCPA as we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. For the purposes of this Section and our compliance with the CCPA, “personal information” does not include publicly available information from government records, deidentified or aggregated consumer information or information specifically excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data or personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. As a financial institution, much of the personal information that we collect from you may be subject to one or more of these laws, including, without limitation, the GLBA, and thus excluded from the CCPA’s scope. To the extent that personal information is not excluded from the CCPA’s scope, the CCPA may apply.
With respect to personal information within the scope of the CCPA, we have collected and disclosed for a business purpose the following categories of personal information from clients who are California residents within the last twelve (12) months:
|Category||Examples||Collected||Disclosed for Business Purpose|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information).||YES||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO||NO|
|F. Internet or other similar network activity.||Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.||YES||YES|
|G. Geolocation data.||Physical location or movements.||NO||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES||NO|
The CCPA provides California residents with specific rights regarding their personal information. This Section describes those rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights. If you are a California resident, you have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you: the categories of personal information that we collect, the categories of sources from which the personal information is collected, the business or commercial purpose for which we collect the personal information, the categories of third parties with whom we share the personal information, the categories of personal information which were disclosed for a business purpose in the last twelve (12) months, the specific pieces of personal information collected about you or disclosed for a business purpose in the preceding twelve (12) months. Specific pieces of personal information collected about you or disclosed for a business purpose within the last twelve (12) months will be broken down according to the enumerated categories in California Civil Code Section 1798.140(o)(1).
Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us, or our service provider(s), to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his/her free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the data protection laws, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the data protection laws that can resultin different prices, rates, or quality levels.
Exercising Access, Data Portability, and Deletion Rights. For a California resident to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through one of the following:
- By telephone at 866-787-4600
- By email at email@example.com
- By mail at 7701 Forsyth Boulevard, Suite 1100, St. Louis, MO 63105
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request made pursuant to the CCPA within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the twelve (12)-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
No Personal Information Selling. We do not sell any personal information that we collect or use.
Transfers of Personal Information
When we transfer personal information to countries other than the country where it was provided, we do so in compliance with applicable data protection laws.
If we transfer personal information subject to a third party, the recipient will have the same level of protection as required of us under applicable data protection laws. All such service providers are bound by contract to refrain from using the personal information we collect from you for any purpose other than providing service to us.
- By telephone at 314-727-4600
- By email at firstname.lastname@example.org.
- By mail at 7701 Forsyth Boulevard, Suite 1100, St. Louis, MO 63105