Protecting Your Privacy

At Sentinel Trust Company, LBA (“Sentinel Trust”) maintaining the trust and confidence of our clients is of paramount importance. This Privacy Policy is intended to summarize the personal information we may collect and maintain during the course of our relationship, our policy regarding the use of that information, and the steps 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.

Information That We Collect

We collect and process information, including nonpublic personal information, that you provide to us in connection with our providing financial services to you, that we receive from third parties or other advisors with whom you work or with whom we engage, that we gain access to or generate to service your account, and as collected through our website or our client portal. Some examples of the information we may collect:

  • Contact details, such as your name, address, e-mail address, social security number, driver’s license or passport number, and date of birth;
  • Payment and financial information such as your income, assets, investment preferences, bank account and credit card numbers, investment commitments, capital calls, distributions, quarterly performance reports, etc.;
  • Usernames, passwords, and account information such as purchases, sales, account balances, etc.;
  • Records of personal or real property, information about your beneficiaries, and trust and estate-planning related documentation;
  • Information to process transactions or to conduct online transactions; and
  • Information when you interact with and navigate our website and our client portal, such as the type of browser you use, details of the web pages you have viewed, your IP and device address, your Cookie ID, etc. See our Terms of Use for information about client portal and cookie policy.

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. We may ask to see and collect other information that will allow us to identify you in accordance with legal requirements.

Information That We Disclose

We use or share nonpublic personal information in a limited and carefully controlled manner. Sentinel Trust generally does not disclose nonpublic personal information about its clients or former clients to anyone, except: (i) in furtherance of our business relationship with certain providers necessary to affect transactions and services (i.e., broker-dealers, insurance agents, investment fund administrators, custodians, etc.); (ii) regulatory bodies; (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law or consented to by you. When we do provide your information to a third party, such as a vendor, we require that the third party adhere to privacy principles, similar to those to which Sentinel Trust adheres for keeping information confidential. 

Information Security

The security of your information is important to us. We maintain physical, electronic, and procedural safeguards that comply with applicable legal standards to secure the confidentiality of your information, including your nonpublic personal information. We educate our employees on our privacy and confidentiality policies and hold them accountable for compliance. Nevertheless, no method of transmission over the internet, or method of electronic storage, is 100% secure and thus, we cannot guarantee its absolute security.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will provide you with an annual reminder of our Privacy Policy. Additionally, if there are material changes in how we handle your nonpublic personal information, we will timely provide the revised Privacy Policy.

Personal Information Related to Children

Our site is intended for adults, and we do not knowingly collect, maintain, or use personally identifiable information from children under age 13 on our website. In accordance with the Child Online Privacy Protection Act, in the event that we learn that we have collected personal information from a child under the age of 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any personal information from or about a child, please contact us by e-mail using the subject heading “COPPA Inquiry” at info@sentineltrust.com.

Your Rights and Choices

Subject to applicable law, you have certain rights and choices regarding your personal information, including:

  • Accessing, updating, or correcting your personal information,
  • Opting out of receiving marketing communications,
  • Requesting your personal information to be deleted, subject to legal requirements.

To the extent applicable, you may exercise any of these rights by contacting us. We will respond to your requests in accordance with the applicable law and/or regulation governing the use of the given personal information.

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

This section applies only to residents of the State of California and is provided in accordance with the California Consumer Privacy Act (“CCPA”). If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what Sentinel Trust will do in response.

We may collect information that constitutes “personal information” under the CCPA. For the purposes of this Section and our compliance with the CCPA, “personal information” does not include publicly available information from government records or covered by certain sector-specific privacy laws, including, for example, the Gramm-Leach-Bliley Act and the Fair Credit Reporting Act.

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:

  • Identifiers, such as name, address, email address, Social Security number, and other similar identifiers;
  • California Customer Records personal information, such as insurance policy number, bank account number, credit card number, or any other financial information, and health insurance information;
  • Classifications, such as sex and marital status;
  • Commercial information, such as records of personal property, products, or services purchased, obtained, or considered;
  • Internet or similar activity, such as browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.
  • Professional or employment-related information, such as current or past work history.

If you are an individual who resides in California and whose personal information is collected and processed by us, you may have the right to:

  • Request that we disclose, free of charge, the categories and specifics of the nonpublic personal information we collect about California residents, the sources from which the information was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting the information.
  • Choose to opt-out of the sale of personal information. Note, Sentinel Trust does not sell this information.
  • Request that we delete the nonpublic personal information we have collected, subject to recognized CCPA exceptions.

We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this privacy policy.

If you choose to contact us with a request, you will need to provide us with identifying information that matches the nonpublic personal information we currently have about you. We will acknowledge receipt of all requests and will advise you how long we expect it will take to respond. We endeavor to process all verified requests within 45 days but will provide you with an explanation if we encounter a delay. We will advise you if we are not able to honor your request.

You have a right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact info@sentineltrust.com or (713) 529-3729.

For clients with disabilities who need to access this policy an in alternative format, please contact data info@sentineltrust.com or (713) 529-3729.

How To File a Complaint

Sentinel Trust is chartered under the laws of the state of Texas and by state law is subject to regulatory oversight by the Texas Department of Banking. Any consumer wishing to file a complaint against Sentinel Trust should contact the Texas Department of Banking through one of the means indicated below:

In Person or US Mail:

Texas Department of Banking
Consumer Assistance Activities
2601 North Lamar Boulevard
Austin, Texas 78705-4294

Telephone No.: 1.877.276.5554 (toll free)
E-mail: consumer.complaints@dob.texas.gov
Website: http://www.dob.texas.gov/file-complaint

Contact Us

We appreciate your confidence in us. Should you have any questions about this Privacy Policy or any aspect of your account administration at Sentinel Trust, please contact your Senior Relationship Officer or Lissa S. Gangjee, President and Chief Executive Officer, at (713) 529-3729. You may also contact us using the e-mail reply function located on our web site, www.sentineltrust.com, or e-mail inquiries directly to us at info@sentineltrust.com.