Last Updated: July 26, 2023
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.
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 may use nonpersonal information to deliver interest-based content to you, and if we do associate any nonpersonal 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 of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “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.
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 e-mail or by posting notice on the Services.
Lastly, we may also disclose nonpersonal 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.
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.
Like many websites, the Services use a standard computer technology called “cookies” to collect personal and nonpersonal 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.
Your operating system and web browser may allow you to erase information stored in 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. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.
You can opt out of receiving our newsletters, event invitations, and other marketing e-mails by clicking on the “manage my subscriptions,” “manage preferences,” “unsubscribe,” or similar link provided 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 firstname.lastname@example.org if you do not want your information used for further marketing. However, if you are a customer of Glenmede, then please note that 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.
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 thirty (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 requestors 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 email@example.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. We will also honor “do not track” features and similar signals to the extent required by applicable laws.
Special Notice to California Residents
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.
We do not Sell or Share (as each of those terms are defined by the CCPA) personal information, nor have we Sold or Shared personal information in the past twelve (12) months.
We retain each category of your personal information for no longer than is reasonably necessary for one or more Business Purposes, subject to your right to request we delete your personal information. Due to the nature of our Services, it is not possible to predict the length of time that we intend to retain your personal information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your personal information for one or more disclosed Business Purpose(s): whether there is a retention period required by statute or regulations; the pendency of any actual or threatened litigation for which we are required to preserve the personal information; the pendency of applicable statutes of limitations for potential legal claims; and generally accepted best practices in our industry. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed Business Purpose(s) based on the above criteria, we will delete your personal information.
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. You further have the right to request that we correct any of your personal information that is inaccurate, provided that we may deny your correction request if the personal information is accurate, and we may also delete your personal information instead of correcting it to the extent such deletion would not negatively impact you. Lastly, you also have the right to request a copy of your personal information, and/or to request that we transmit your personal information to another entity. 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.
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.
Glenmede Investment Management LP
1650 Market Street, Suite 1200