An Important Notice Concerning Your Privacy
At the New Covenant Funds (the ‘‘Funds’’), we are committed to handling personal information responsibly. We recognize and respect the privacy expectations of those who purchase shares of the Funds and believe the confidentiality and security of personal financial information communicated to us is one of our fundamental responsibilities.
Our privacy policy applies only to Fund investors who have a direct customer relationship with us. If you own Fund shares through a relationship with a third-party broker, bank, investment advisor, or other financial service provider, that third party’s privacy policies may apply to you and our privacy policies may not.
Our privacy policy will continue to cover information we may collect about you at the time you apply to purchase shares of the Funds, during the time you hold shares and after your account is closed. Please note that we may amend this Notice at any time and will inform you of any changes to this Notice as required bylaw.
We Respect Your Privacy
We appreciate that you may have provided us with personal financial information. We strive to maintain the privacy of such information. This Notice describes what non-public personal information we collect about you, why we collect it, and when we may share it with others, including entities affiliated with us, such as the Presbyterian Foundation and the New Covenant Trust Company, N.A. (collectively ‘‘our affiliated companies’’), as well as with those not affiliated with us. We hope this Notice will enable you to understand how we collect and share non-public personal information that we gather about you. Throughout this Notice, we refer to the non-public information that personally identifies you or your accounts as ‘‘personal information.’’
- What personal information do we collect about you?
To serve you better and manage your account, it often is important that we collect and maintain accurate information about you. We may obtain this information from forms you submit to us, from your dealings with us, from our Web sites, and from other sources.
For example:
- Account applications and other forms submitted by shareholders of the Funds;
- Correspondence, written or electronic, or telephone contacts with shareholders of, or consumers inquiring about, the Funds;
- Transaction history of shareholder accounts with the Funds; or
- Other sources in connection with making available Fund shares or other services.
- When Do We Disclose Personal Information We Collect About You?
To serve you better and manage your account, we may disclose personal information we collect about you to our affiliated companies and to non-affiliated third parties as set forth below.
- Information we disclose to our affiliated companies
In order to manage your account(s) effectively, including servicing and processing your transactions, to let you know about products and services offered by us and our affiliated companies, and as otherwise required or permitted by law, we may disclose personal information to our affiliated companies. Offers for products and services from our affiliated companies are developed under conditions designed to safeguard your personal information.
- Information we disclose to third parties
We do not disclose personal information that we collect about you to non-affiliated third parties, except to enable them to provide services on our behalf, to perform certain joint marketing and servicing agreements with other financial institutions, or as otherwise required or permitted by law. For example, some instances where we may disclose information about you to non-affiliated third parties include: for servicing and processing transactions, to offer our own products and services, to protect against fraud, for institutional risk control, to respond to judicial process or to perform services on our behalf. When we share personal information with these companies, they generally are required to limit their use of personal information to the particular purpose for which it was shared and they generally are not allowed to share personal information with others except to fulfill that limited purpose.
- Information we disclose to our affiliated companies
- How Do We Protect the Security and Confidentiality of Personal Information We Collect About You?
We maintain physical, electronic and procedural security measures to help safeguard the personal information we collect about you. We have internal policies governing the proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information, and we require them to adhere to confidentiality standards with respect to such information.
- How Can You Limit the Sharing of Certain Types of Personal Information with our Affiliated Companies?
We respect your privacy and offer you choices as to whether we share with our affiliated companies personal information that we collected to determine your eligibility for products and services you request (‘‘eligibility information’’). Please note that, even if you direct us not to share eligibility information with our affiliated companies (‘‘eligibility opt out’’), we may still share personal information, including eligibility information, with those companies in circumstances excluded from the opt out under applicable law, such as to process transactions or to service your account. We may also share certain other types of personal information with our affiliated companies such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us. If you wish to opt out, you may do so by:
- Calling us at 800-858-6127
- Writing to us at the following address: One Freedom Valley Drive, Oaks, PA 19456
Additionally, independent of your right to direct us not to share your eligibility information with our affiliated companies, you may limit our affiliates from marketing (‘‘marketing opt out’’) their products or services to you based on eligibility information that we share with them. This limitation does not apply in certain circumstances, such as if you currently do business with one of our affiliates or if you ask to receive information or offers from them. If you wish to limit such marketing offers, you may do so by:
- Calling us at 800-858-6127
- Writing to us at the following address: One Freedom Valley Drive, Oaks, PA 19456
If you choose to write to us for either eligibility opt out or marketing opt out, your written request should include your name, address, telephone number and account number(s) to which the opt out applies and should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party. If you have previously notified us about your privacy preferences, it is not necessary to do so again unless you decide to change your preferences. Your opt-out preference will remain in effect with respect to this policy (as it may be amended) until you notify us otherwise in writing. If you have a joint account, your direction for us not to share this information with our affiliated companies will be applied to all account holders on that account.
- Important Information for Residents of Vermont and California
If you are a resident of Vermont, you are automatically considered to have opted out of sharing with our affiliated companies. Additionally, if you are a resident of Vermont, we will only share your personal information pursuant to a joint marketing agreement as allowed by applicable law. If you are a California resident, you have additional rights to limit how we use your personal information. Please refer to the document entitled ‘‘Important Privacy Choices for Consumers.’’