Privacy and Cookies Policy

Glenmede is committed to maintaining your privacy, and for that reason we have adopted this Privacy and Cookies Policy (this “Privacy Policy”) for the ImpactivateSM website (the “Website”). The following discloses how we gather, use, and disclose data obtained via the Website. This Website is provided by The Glenmede Trust Company, N.A. (“Glenmede”, “we”, “our”, or “us”).
 
This Privacy Policy applies to information Glenmede collects through this Website; however, it does not apply to information collected from our employees, contractors, or vendors. Additionally, this Privacy Policy does not apply to information collected from users by Glenmede in connection with other Glenmede products or services, such as information collected on Glenmede.com. It also does not apply to information that you share with third parties or is collected by third parties through the Website (including web traffic analytics tools). You acknowledge and agree that Glenmede is not responsible for the data collection or use practices of any third party utilized in providing the Website.
 
By accessing and using this Website, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Website. Information gathered through the Website may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the Website, you agree to the transfer, use, and storage of your personal information (as described below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Website are deemed to occur in the United States, where our servers are located.

Your Information

Personal information that may be collected by us includes your name, address, e-mail address, and other information that can be reasonably used to identify you. Glenmede will only collect a limited amount of personal information from you through the Website, as we do not engage in any transactions with you on or through this Website.
 
We also collect non-personal information relating to the Website, that is, information that does not personally identify an individual. The non-personal information we collect includes how you interact with the Website, information generally collected or “logged” by Internet Websites or Internet services when accessed or used by users (such as your IP address, or HTTP header information), and information about your web browser or device accessing or using the Website. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-personal information. We will not use non-personal information to try to identify you, and if we associate any non-personal information with information that personally identifies you, then we will treat it as personal information.
 
We may use the information we collect to:
• Assist us in providing, maintaining, and protecting the Website;
• Improve the Website;
• Communicate with you, such as provide you with newsletters, RSS feeds, and/or other communications relating to the Website; and
• Manage and maintain the systems that provide the Website.
 
We will not sell or transfer your information to third parties for purposes of marketing their products or services to you. However, Glenmede may share your information with Glenmede personnel and other Glenmede service providers who are engaged to perform functions on our behalf, such as hosting the Website, providing data storage, conducting audits of the Website, and answering questions you may have. Such service providers may be located in the United States or Canada. In addition, Glenmede may also disclose personal information as we believe to be necessary to meet legal, regulatory, insurance, audit, and security requirements; to protect the rights, property, or safety of us, or other users, or third parties; to prevent a crime or protect national security; or to detect, prevent, or otherwise address, fraud, security, or technical issues.
 
In addition, we reserve the right to transfer information (including your personal information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Website, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such a transfer, for example via email or by posting notice on this Website.
 
Lastly, we may also disclose non-personal information, aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

Information Security

We utilize reasonable information security measures to safeguard your personal information against unauthorized access, modification, or destruction. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its security.

Cookies

Like many websites, we use a standard computer technology called “cookies” to collect non-personal information regarding your use of the Website. For example, to improve our Website, we collect how, when, and which parts of the Website or its features you use, and we may use your device’s unique identifier (UDID), media access control address (MAC Address), or other unique identifiers to assist us in collecting and analyzing this data. A “cookie” is a small amount of data that a Website operator, or a third party whose content is embedded in that Website, may store in your web browser and that the Website operator or, as applicable, the third party, can access when you visit the Website. In addition, we may use cookies provided by Google Analytics so that we can track our visits and analyze other information about the user activity on the Website. The cookies we use cannot retrieve any data from your hard drive.
 
Google Analytics is subject to its own privacy policy, which you can read here. If you wish, you can opt out of Google Analytics using this link: https://tools.google.com/dlpage/gaoptout/

Marketing

Glenmede will not send you general commercial or marketing emails other than our newsletters and event invitations. You can opt out of receiving our newsletters and event invitations by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Please also note that you can also email us at privacy@impactinvestingexchange.com if you do not want your information used for further marketing.

Other Sites

This Website may contain links to other third-party websites. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy or security policies or practices of such other third-party websites. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share, and protect your information.

Access to and Accuracy of Personal Information

You can request access to your personal information which Glenmede has collected in order to verify, update, and correct it, and to have your personal information removed. Please submit this request in writing, and we will use reasonable efforts to respond within 30 days of our receipt of your request. However, in either case, we may need to retain your information for legal reasons or for legitimate business purposes, such as for audit or dispute resolution purposes. Your right to access your personal information is subject to applicable legal restrictions. There is no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records or if a special expense is involved in retrieving your information, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, request concerning information residing on backups, or relate to information that is not associated with your personal information. We will advise you of any charges in advance. You may submit requests regarding your personal information to privacy@impactinvestingexchange.com.

Children

The Website is not intended for users under 18 years of age. We do not knowingly collect personal information from users under 18 years of age. We do not authorize users under 18 years of age to use the Website.

Changes to Privacy Policy

Glenmede may modify or update this privacy policy from time to time, with or without prior notice by posting an update on this page. Please review the “Last Updated” date at the top of the page when you visit the Website to determine if the Privacy Policy has been revised since the last time you visited. IF YOU DO NOT AGREE TO CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE WEBSITE AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE OF THIS PRIVACY POLICY).

Questions

To ask questions about this Privacy Policy or to lodge a complaint, contact us at:

The Glenmede Trust Company, N.A.
1650 Market Street, Suite 1200
Philadelphia, Pennsylvania 19103
Email: privacy@impactinvestingexchange.com

Effective Date: 2/26/2018