Privacy Notice - California Residents
Pursuant to the California Consumer Privacy Act (herein “CCPA”), this Privacy Notice is a supplemental disclosure for California residents, and is to be read in conjunction with the information contained in the Privacy Policy of Summit Trail Advisors LLC (“STA”).
What is Personal Information?
As defined by the CCPA “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:
- Identifiers, including but not limited too: his or her 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. (subdivision (e) of Section 1798.80 of the California Civil Code)
- Any categories of personal information described in above.
- Characteristics of protected classifications under California or federal law.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information.
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
- Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information does not include:
“Personal information” does not include publicly available information. For purposes of this paragraph, “publicly available” means information that is lawfully made available from federal, state, or local government records. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge.
Information (“STA”) collects about you
(“STA”) does not sell Personal Information and will not sell Personal Information relating to you, including within the meaning of the CCPA within the past 12 months. “Sell” or “sold” means the disclosure of Personal Information to a third party for monetary or other valuable consideration.
We may collect, use, store, and transfer different kinds of Personal Information about you for business or commercial purposes depending on our relationship or interaction with you which we have grouped together as follows:
Category | Examples | Purpose |
Identifiers | First name, maiden name, last name, user name or similar identifier, marital status, date of birth, gender. |
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Characteristics of protected classifications under California or Federal Law | Records of products or services purchased, or considered, other purchasing or consuming histories or tendencies. |
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Commercial Information | Records of products or services purchased, or considered, other purchasing or consuming histories or tendencies. |
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Biometric information | Genetic, physiological, behavioral, and biological characteristics. |
N/A - STA will not collect Biometric information |
Internet or Electronic Data | Information regarding a consumer’s interaction with an internet website, application, or advertisement. |
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Geolocation Data | Physical location. |
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Sensory Data | Audio, electronic, and visual information |
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Professional Related Data | Work history, prior employer. |
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Education-related Data | School or school[s], and date of graduation. |
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Inferences | Drawn from any of the information identified in this table to create a profile about a consumer reflecting the consumer’s preferences. |
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We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, documents that are provided by clients as they relate to the services engaged by the client.
- Indirectly from our clients or their agents. For example, through information collected from clients through the course of provided services to each client.
- From third parties that interact with us in connection with the services we perform or the products we provide. For example, from outside companies, we may use to assist us in providing you with our services or products.
- Directly and indirectly from the activity on our website or third-party websites through which we advertise. For example, from submissions through our website or website usage details collected automatically.
Sharing of Personal Information
(“STA”) shares your Personal Information with third parties and service providers when necessary for business purposes. When (“STA”) shares your Personal Information, it is contractually protected by both (“STA”) and the applicable third party or service provider in question.
The categories of Personal Information we may share may include the categories listed above.
The categories of third parties we may share your Personal Information with include: our affiliates and subsidiaries, service providers performing necessary business functions, financial advisors registered with (“STA”), financial institutions with networking agreements with (“STA”), introducing broker-dealer or registered investment advisers, financial product and service companies and law enforcement, self-regulatory organizations (e.g., FINRA), and regulators as required by law.
Your Rights
Under the CCPA, you have specific rights regarding your Personal Information held by private companies. The below section describes your rights and how to exercise them.
Disclosure
You have the right to ask us to disclose to you any Personal Information we have collected about you in the last 12 months. In order to exercise this right, (“STA”) must first verify your identity to ensure it is a legitimate request, and then disclose to you:
- The categories of Personal Information we have collected about you
- The types of sources used to collect Personal Information about you
- The types of third parties with which we have shared any of your Personal Information (if applicable).
- The business or commercial purpose(s) for collecting your Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- The categories of Personal Information that have been disclosed for a business purpose that each category of recipient obtained.
Deletion
You have the right to request that we delete the Personal Information we have collected from and about you. In order to exercise this right, (“STA”) must first verify your identity to ensure it is a legitimate request, we will then delete the relevant information unless an exemption applies (CCPA 1798.105).
We may deny your deletion request if retaining the information is necessary for us or our service providers 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 their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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.
To exercise the access, data portability, or deletion rights described above please submit a verifiable consumer request via the phone number or email address below in the “Contact Information” section of this notice.
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. If an authorized agent submits a request on your behalf, you may be asked to verify your identity directly with (“STA”). 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; and
- 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. Making a verifiable consumer request does not require you to create an account with us. 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 within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response using the contact information we have on file for that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 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.
Non-Discrimination
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA (CCPA §1798.125).
Changes to Our Privacy Notice
(“STA”) reserves the right to update or change the information contained in this privacy notice at any time. In the event of a substantive change to our policies, we will notify you and may request your explicit consent as necessary. We suggest you visit our website (Advisor Website) periodically to learn of any changes to our Notice.
Contact Information
If you have any questions pertaining to this notice or if you wish to exercise your rights under California law, you can contact us at: