Website Privacy & Cookies Policy

Last Updated: 12.4.2020

 

Glenmede is committed to maintaining your privacy, and for that reason we have adopted this Website Privacy and Cookies Policy (this “Privacy Policy”) for the Glenmede website (www.glenmede.com), the Impactivate® website (www.theimpactivate.com), and any other websites, tools, products, or services provided by Glenmede that link to or reference this Privacy Policy (collectively, the “Services”). The following discloses how we gather, use, and disclose data obtained via the Services. The Services are provided by The Glenmede Trust Company, N.A. (“Glenmede”, “we”, “our”, or “us”) and are intended for individuals within the US.

 

This Privacy Policy applies to information Glenmede collects through the Services, as well as other information provided to us online or offline by third parties, when we associate that information with users of the Services; 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 Glenmede’s financial products or services, which information is governed by Glenmede’s U.S. Consumer Privacy Notice. It also does not apply to information that you share with third parties or is collected by third parties through the Services (including web traffic analytics tools). You acknowledge and agree that the data collection or use practices of certain third parties utilized in providing the Services may be governed by such third parties’ own privacy policies.

 

You may also receive an additional privacy notice in connection with your use of a particular online product or service provided by Glenmede, such as GlenmedeConnect, that supplements this Privacy Policy as further described in such additional privacy notice (a “Supplemental Privacy Notice”). In the event of any conflict or inconsistency between this Privacy Policy and any Supplemental Privacy Notice, the Supplemental Privacy Notice will control with respect to the information that is governed by the Supplemental Privacy Notice.

 

This Privacy Policy describes, among other things:

 

• Personal and other information we collect about you;

• How we use your information;

Rights that you may have if you reside in the State of California;

• How we may share your information with third parties; and

• Your choices regarding the personal information we collect about you.

 

By accessing and using the Services, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services. Information gathered through the Services 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 Services, 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 Services are deemed to occur in the United States, where our servers are located.

 

Your Information

 

When you register for or use the Services, we may collect personal information including but not limited to your name, telephone number, postal address and e-mail address (collectively, “General Identifiers”), and other information that can identify or be reasonably linked to you, such as your IP address (collectively, “Online Identifiers”). Glenmede will only collect a limited amount of personal information from you through the Services, as we do not engage in any transactions with you on or through the Services.

 

You may choose not to provide personal information (subject to the controls offered by your device’s operating system), but this may prevent you from using or accessing certain features of the Services.

 

We also collect non-personal information relating to the Services, that is, information that cannot identify or reasonably be linked to an individual. The non-personal information we collect includes how you interact with the Services, information generally collected or “logged” by websites or other Internet services when accessed or used by users (such as the content you access on the Services). As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-personal information.

 

We may use non-personal information to deliver interest-based content to you, and if we do associate any non-personal information with personal information, then we will treat the associated information as personal information.

 

We may use the information we collect for the following “Business Purposes”:

 

• Assist us in providing, maintaining, and protecting the Services;

• Improve the Services;

• Communicate with you, such as provide you with newsletters, RSS feeds, and/or other communications relating to the Services;

• Send or display offers and other content that is customized to your interests or preferences;

• Manage and maintain the systems that provide the Services; and

• For any other acceptable purposes as set forth in the data privacy laws and regulations that may apply to your personal information, such as the California Consumer Privacy Act (“CCPA”).

 

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 Services, providing data storage, conducting audits of the Services, and answering questions you may have. When we use a service provider, we require that the service provider use and disclose personal information received from us only to provide their services to us or as required by applicable law. Such service providers may be located in the United States or Canada.

 

We may also disclose personal information and non-personal information to online tool providers. By “online tool provider” we mean a licensor of software that we include in, or use with, the Services, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of personal information and/or non-personal information to the online tool provider. Online tool providers may have the right to use personal information and non-personal information about you for their own business purposes. Use and disclosure of personal information and non-personal information by an online tool provider is described in its privacy policy. See the “Cookies” section below for some of the key online tool providers we use.

 

Additionally, Glenmede reserves the right to monitor and archive electronic communications made via the Services to the extent permitted or required by law.

 

In addition, Glenmede may also disclose personal information as we believe to be necessary to enforce or apply the terms and conditions of the Services; 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 Services, 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 the Services.

 

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, the Services use a standard computer technology called “cookies” to collect personal and non-personal information regarding your use of the Services. For example, to improve our Services, we collect how, when, and which parts of the Services 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. A “cookie” may also refer to a web-browser-based storage provided by Adobe’s Flash plugin (a “flash cookie”).

 

Your operating system and web browser may allow you to erase information stored in cookies, flash cookies, and local browser storage. But if you do so, you may be forced to login to the Services again and you may lose some preferences or settings. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of our Services may not function properly without it. More information about managing cookies is available here. Cookie management tools provided by your browser may not affect flash cookies. More information about managing flash cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

 

An online tool provider may collect information automatically, in which case personal information and non-personal information it receives are subject to the online tool provider’s privacy policy. Some online tool providers may allow you to opt out of certain collection and/or uses of your information. You can read more here:

 

Google Analytics

 

Pardot (provided by Salesforce)

 

Marketing

 

You can opt out of receiving our newsletters, event invitations, and other marketing e-mails 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@glenmede.com if you do not want your information used for further marketing. Also, even if you opt out of marketing e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

 

Other Sites

 

The Services 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 connection with the Services 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. We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests. 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@glenmede.com.

 

We support the development and implementation of a standard “do not track” browser feature that provides users with control over the collection and use of information about their web-browsing activities. Once a standardized “do not track” feature is released, we intend to adhere to the browser settings accordingly.

 

Special Notice to California Residents

 

This section – Special Notice to California Residents – supplements the information contained in our Privacy Policy and applies only if you reside in the State of California (you are a “California Consumer”).

 

In the past twelve (12) months, Glenmede has collected General Identifiers and Online Identifiers from California Consumers who use the Services. We obtain this information directly from you (for example, from forms you complete on the Services) and indirectly from you (for example, from information that is automatically sent by your web browser or from analyzing data about your actions on our Services). We may also obtain information offline from third parties, which we treat as personal information when we associate it with California Consumers that use the Services.

 

Glenmede may use or disclose personal information for each of the Business Purposes described in this Privacy Policy. Unless we notify you otherwise, we will not collect additional categories of personal information, nor use the personal information we collect for any other materially different, unrelated, or incompatible purposes.

 

In the past twelve (12) months, Glenmede has disclosed personal information to third parties as described in the “Your Information” and “Cookies” sections of this Privacy Policy. We do not Sell (as defined by the CCPA) personal information, nor have we Sold personal information in the past twelve (12) months.

 

If you are a California Consumer, you may request certain information about our collection, use and disclosure of your personal information over the past twelve (12) months, whether or not it was collected electronically. You also have the right to request that we delete any of your personal information that we collect or maintain; however, we reserve the right to deny your deletion request in accordance with the CCPA, as well as to the extent we may be required to retain your information pursuant to another applicable law or regulation. We also reserve the right to verify all such requests, in accordance with the CCPA, to confirm that the information provided in connection with a request matches the personal information maintained by us.

 

California Consumers can submit requests and exercise their rights under the CCPA by contacting us as set forth in the “Questions” section below. If you choose to exercise a privacy right under the CCPA, you have the right not to receive discriminatory treatment. However, please be aware that it may be a functional necessity for our Services to have personal information about you in order to operate, and we may not be able to provide some or all of our Services features or content to you if you direct us to delete your personal information.

 

Children

 

The Services are 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 Services.

 

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 Services 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 SERVICES 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@glenmede.com