Privacy policy

Crossmarc Steward is a private family-office platform operated by Crossmarc, LLC, a Colorado limited liability company ("Crossmarc," "we," "us," or "our"). This policy describes how we collect, use, store, and protect personal and financial information when you use the Steward platform at steward.crossmarc.com and the associated web application.

If you have questions about this policy, contact us at privacy@steward.crossmarc.com.

We collect information in two ways: information you provide directly, and information collected automatically.

Information you provide: name, email address, and any content you upload or enter — including document files, entity descriptions, account labels, and notes. We also collect billing information when you subscribe, processed through a third-party payment provider (Stripe).

Information collected automatically: account balances, investment holdings, and liability details from financial institutions you connect through Plaid (see Section 4); authentication tokens; access logs (IP address, browser type, timestamp) retained for 90 days for security purposes.

We do not collect sensitive personal information beyond what is necessary to provide the service (e.g., social security numbers, passport numbers). If you choose to store such information in your document vault, it is encrypted and access-controlled as described in Section 5.

We use the information we collect solely to:

• Provide, maintain, and improve the Steward platform;
• Authenticate you and enforce the access controls you configure;
• Aggregate and display your financial data in your net-worth dashboard;
• Send transactional communications (e.g., account verification, security alerts);
• Process billing and subscription management;
• Investigate security incidents and enforce our terms of service.

We do not use your data for advertising, profiling, or to train machine learning models. We do not sell, rent, or share your personal or financial data with any third party for their marketing purposes.

If you choose to connect financial institutions, we use Plaid Technologies, Inc. to establish and maintain those connections. Plaid acts as a data processor on our behalf and is subject to its own End User Privacy Policy. The connection is read-only: neither Plaid nor Steward can initiate transactions or modify your accounts.

Your bank credentials are entered directly on a Plaid-hosted interface and are never transmitted to or stored on Crossmarc's servers. Plaid holds SOC 2 Type II certification and maintains data-access agreements directly with financial institutions.

You can disconnect any institution at any time within Steward. We will immediately revoke the corresponding Plaid access token and cease requesting data from that institution.

Other than Plaid and Stripe (billing), we do not share your data with third-party service providers except as required by law or as necessary to defend legal claims.

All data in transit is encrypted using TLS 1.2 or higher. Data at rest is encrypted using AES-256 on AWS infrastructure, with encryption keys managed through AWS Key Management Service.

Security is enforced at the application layer, not just by the cloud provider. Every record is tagged to your workspace, and that boundary is checked on every request — your data is never returned outside it. Secrets you store in the credential vault are additionally encrypted at the application layer and cryptographically bound to your workspace before they are written.

Access to your data is restricted to the members you explicitly invite, and every account is protected by multi-factor authentication. No Crossmarc employee can access the contents of your workspace or document vault without your explicit authorisation, except to investigate a reported security incident.

Documents stored in the vault are held in private AWS S3 object storage with no public URLs. Download links are time-limited and scoped to the requesting authenticated user. For a fuller description of our architecture, see our security overview.

We retain your account data and documents for as long as your subscription is active. Access logs are retained for 90 days and then permanently deleted.

If you cancel your subscription, your data remains accessible for 30 days to allow export. After that period it is permanently removed from our active production systems. Residual copies may persist in encrypted, access-controlled system backups for a limited period — no longer than 35 days — until those backups are cycled out and overwritten in the ordinary course; backup copies are never restored to active use for any purpose other than disaster recovery. We do not retain financial records beyond this window.

You have the right to access, correct, export, or delete your personal information at any time. To exercise these rights, contact us at privacy@steward.crossmarc.com. We will respond within 30 days. We will never deny you service, charge a different price, or provide a different level of service because you exercised any of these rights.

California residents (CCPA / CPRA). Regardless of whether we meet the statutory thresholds, we honour the rights California law provides: the right to know what personal information we hold, to access and port it, to correct it, and to request its deletion. We do not "sell" or "share" your personal information as those terms are defined under California law, and we do not use it for cross-context behavioural advertising.

EEA / UK residents (GDPR / UK GDPR). Our legal bases for processing are: performance of a contract (to deliver the platform you subscribe to); legitimate interests (to secure and operate the service, including access logging); consent (to connect a financial institution through Plaid, which you may withdraw at any time by disconnecting that institution); and legal obligation where applicable. You also have the right to object to or restrict processing, the right to data portability, and the right to lodge a complaint with your local supervisory authority.

This marketing site does not use tracking cookies or third-party analytics. The Steward application uses session cookies strictly necessary for authentication. We do not use advertising cookies.

We may update this policy from time to time. Material changes will be communicated to active subscribers by email at least 30 days before taking effect. Continued use of Steward after that date constitutes acceptance of the revised policy.

Crossmarc, LLC
privacy@steward.crossmarc.com

For general enquiries: steward.crossmarc.com/contact