The nature and importance of our client relationships require the highest standards of confidentiality and discretion.  We have prepared this Privacy Policy to provide our clients with a summary of the personal information that we may collect and maintain during the course of our relationship, our policy regarding the use of that information, and the measures we take to safeguard that information.  We do not sell personal information to anyone and only share it with others as described in this Privacy Policy or with your prior consent. 

This Privacy Policy describes the privacy practices of St. Louis Family Office, Inc. and its wholly-owned subsidiary, The St. Louis Trust Company dba ArchBridge Family Office (collectively referred herein to as “ArchBridge,” “we,” “our,” or us”). This Privacy Policy applies to personal information we collect through our website: https://archbridge.com/ (the “Website”), our client portal (available at: https://www.summitas.com/ext/stlouis) (the “Portal”), messages between clients and us, whether electronically or in person, or any other means in connection with providing services to the client or our business relationship with the client (collectively, the “Services”). This Privacy Policy does not apply to personal information collected from employees, job applicants, contractors, or similar individuals.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. This Privacy Policy may change from time to time (as described below in the Changes to Our Privacy Policy section).

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:

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 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

ArchBridge Family Office 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:

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.

Except as described in this Privacy Policy, we will not otherwise disclose personal information to any third parties unless you have been provided with notice of such disclosure.

Information Security

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

On occasion we may send you links to websites and/or services operated by others (“Third Party Services”).  Each of those Third Party Services maintains its own policies about the collection, use and security of personal information.  We are not responsible for the manner in which others use your personal information, and we make no endorsement of or representation about any such Third Party Services.  We recommend that you review all privacy policies associated with Third Party Services before submitting any information.  We assume no responsibility for and shall not be liable for the privacy, terms of use or other policies of any Third Party Services.

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 ArchBridge Family Office 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:

To the extent applicable, you may exercise any of these rights by contacting us at: privacy@stlouistrust.com

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:

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:

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:

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:

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.

Changes to Our Privacy Policy

As we continue to provide additional Services and as the privacy laws and regulations evolve, it may be necessary to revise or update this Privacy Policy. We reserve the right, at our discretion, to change, modify, add or remove portions of this Privacy Policy at any time. If we make any material changes to this Privacy Policy, including, any material changes to how we collect, use, process, and/or share your information, we will prominently post a notice of such changes on the Website. To the extent required by applicable law, we will contact you with regard to changes to this Privacy Policy.

Your Acknowledgement of This Privacy Policy and When We Ask for Consent

By using our Services, the Portal or the Website, you acknowledge that we are processing your personal information in accordance with this Privacy Policy.  If you do not wish that we process your personal information in this way, please do not use our Services, the Portal or the Website or otherwise provide us with your personal information.

We process your personal information as described in this Privacy Policy. In certain instances, we only process your personal information if you have consented. Where we process your personal information on the basis of your consent, we will ask for your consent explicitly but, in some cases and only where permitted by applicable law, we may infer in a transparent manner consent from your actions. We may also ask you to provide additional consent if we need to use your personal information for purposes not covered by this Privacy Policy.

Contact Us

If clients have any questions regarding this Privacy Policy 0r the security of their personal information, please do not hesitate to contact us at: