Texas Presbyterian Foundation
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Privacy Policy

Texas Presbyterian Foundation (“TPF”) is committed to protecting your privacy. We strongly believe in protecting the privacy of the personally identifiable information you share with us. We also believe it is important to inform you about how we will use your personal data and to give you choices about how those data will be used. Therefore, we encourage you to read this Privacy Policy carefully.

This TPF Privacy Policy (“Privacy Policy”) explains data collection and use practices of the web property “www.tpf.org” (the “Website”). By accessing and using the Website, you consent to the information collection and use practices described in the Privacy Policy. This Privacy Policy is subject to all the terms and conditions set forth in the Terms of Use for this Website that is posted on the bottom of this page.

If you have any questions about the Privacy Policy, you may contact TPF using the information below (the “Contact Information”):

Email:  TPFPrivacy@tpf.org

Write to us at:
Texas Presbyterian Foundation
6100 Colwell Blvd., Suite 250
Irving, TX 75039

If the Privacy Policy changes, we will post an updated version on the Website. The policy revision date will be posted at the bottom of this document.

Why should you share your personal data with TPF?

Sharing your personally identifiable information enables us to offer you a number of benefits. It will make it easier and more convenient for you to:

  • Register your account information
  • Manage your investment fund
  • Receive personalized messages and special offers that are relevant to your interests
  • Save time by storing your preferences

You may choose to share your information with us in a number of ways online, such as by registering your account. The information, as gathered, also will allow us to conduct market research to help provide more responsive customer service and to improve the Website.

Frequently Asked Questions

  • What kind of information does TPF collect about me?
  • How do you use my information?
  • Does TPF share my information with third parties?
  • How do I access my information? How do I change my information?
  • How does TPF protect kids’ privacy?
  • What steps does TPF take to keep my information secure?
  • What about links to other websites and services?
  • What is TPF’s Policy on “Do Not Track” Signals and Third-Party Website Tracking under the California Online Privacy Protection Act (CalOPPA)?
  • Can TPF change this privacy policy?

These questions are answered below:

What Kind of Information Does TPF Collect About Me?

We collect several different types of information for various purposes to provide and improve our Website. Personal Data means data about a living individual who can be identified from such data (or from such data and other information either in our possession or likely to come into our possession). Usage Data is data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).

Personal Data

While using our Website, we may ask you to provide us with certain Personal Data that can be used to contact or identify you. Personal Data may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Security information, such as your username, and password or password hint
  • Transaction information, such as your investment and disbursement instructions, and your transactions and contributions to your fund
  • Billing information, such as credit card, expiration date, billing address and account history
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Usage Data

We may also collect Usage Data. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Website with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Website. This allows us to recognize your computer the next time you visit, without bothering you with another request to register.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Website.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings including the shopping cart.
  • Security Cookies. We use Security Cookies for security purposes.
  • Third-Party Cookies. We use certain third-party cookies as identified in the Data Sharing section below.

If you do not wish to receive cookies, please refer to the “Help” file of your Internet Browser either to learn how to block all cookies or how to receive a warning before a cookie is stored.

To learn more about cookies, we encourage you to visit www.cookiecentral.com.

How Do You Use My Information?

As appropriate, the Personal Data collected on the Website will be used to:

  • operate or improve the Website,
  • provide our many service(s),
  • carry out the transaction(s) you have requested or authorized,
  • notify you about changes to our Website, services, or terms,
  • provide customer support,
  • remember your Website preferences,
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

We do not “sell” your Personal Data.

Promotional Offers from Us

We may use your personal contact data and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (direct marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will not share your personal data with any third party for marketing purposes.

Purpose for Which We Will Use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of Data Lawful Basis for Processing Including Basis of Legitimate Interest
To register you for an account Identifying data; contact information Performance of a contract with you
To process and complete your account requests and allow you to access and manage your accounts Identifying data; contact information; financial information; transactional correspondence; marketing correspondence (a)   Performance of a contract with you;

(b)   Necessary for our legitimate interests (to recover debts due to us; direct marketing)

To manage our relationship with you, including: (a) notifying you about changes to our terms or privacy policy, (b) asking you to leave a review or take a survey Identifying data; contact information; marketing correspondence (a)   Performance of a contract with you;

(b)   Necessary for our legitimate interests (to keep our records updated; direct marketing);

(c)   Necessary to comply with a legal obligation

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identifying data; contact information; usage data; aggregate data (a)   Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise);

(b)   Necessary to comply with a legal obligation

To deliver relevant website and app content to you and measure or understand the effectiveness of the content we serve to you Identifying data; contact information; marketing correspondence; usage data; transactional correspondence; aggregate data Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Usage data; aggregate data Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Identifying data; contact information; marketing correspondence; usage data; transactional correspondence; aggregate data Necessary for our legitimate interests (to develop our products/services and grow our business)
To allow you to make a donation on the Website Identifying data; contact information; financial information; transactional correspondence Performance of a contract with you

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Retention of Data

TPF will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

TPF will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer periods.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. TPF may transfer your data to third parties as set forth herein, but shall maintain responsibility for such data in cases of onward transfer to third parties as required under applicable law.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

TPF will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Does TPF Share my Information with Third Parties?

TPF does not “sell” your data to third parties. TPF may employ third party vendors and service providers (“Service Providers”) to perform various functions on TPF’s behalf. Services provided by Service Providers may include, but are not limited to, (i) managing account information, (ii) processing credit card or check card payments, (iii) analyzing data, (iv) developing, hosting and maintaining the Website and any related databases, or (v) communicating about TPF. TPF does not authorize any of the Service Providers to make any other use of your information or to contact you outside the context of the services related to the Website. TPF may also provide certain information to third parties for marketing purposes.

TPF may also share your information for the following purposes:

Business Transaction

If  TPF is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, TPF may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

TPF may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of TPF and our partners’ data
  • To prevent or investigate possible wrongdoing in connection with the Website
  • To protect the personal safety of users of the Website or the public
  • To protect against legal liability.

Service Providers

We may disclose your Personal Data to our service providers as set forth below. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Payments

We may provide the ability for you to Donate on the Website. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with is: Authorize.net

How Do I Access My Information? How Do I Change My Information?

Your Data Protection Rights

TPF aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of disclosure of the specific pieces of Personal Data collected. You have the right to request disclosure of the specific pieces of Personal Data collected.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data and to opt out of any “sale” of Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where TPF relied on your consent to process your Personal Data.

To exercise any of these rights please contact us as follows:

  • 1-800-955-3155
  • https://tpfprod.wpengine.com/contact
  • TPFPrivacy@tpf.org

Please note that we may ask you to verify your identity before responding to such requests. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

How Does TPF Protect Kids’ Privacy?

TPF does not knowingly sell or market to, solicit information from, or sell products or services for purchases to, individuals under 18 years of age. If you are a parent or legal guardian of a child under the age of 18, and personal information concerning your child has been provided to TPF using the Website, you may contact TPF using the Contact Information provided above and we will delete any and all personal information about your child as soon as reasonably possible.

What Steps Does TPF Take to Keep my Information Secure?

We recognize that it is important to you that we protect the information you entrust to us. TPF uses a variety of secure techniques to protect your information, including secure servers, firewalls, and encryption of financial data.

The Website also may make forums, message boards and/or newsgroups available to you. Please remember that any personally identifiable information you provide in these areas is also available to other users, and you should exercise caution before deciding to disclose such data.

Please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

What About Links to Other Websites and Services?

The Website may contain links to or reference third party websites, resources and advertisers (collectively, “Third-Party Sites”). These Third-Party Sites are not controlled by TPF and, therefore, are not subject to this Privacy Policy. You should check the privacy policies of these individual Third Party Sites to see how your personal information will be utilized by the operators of those Third-Party Sites before providing any personal information. TPF is not responsible for the content or practices of any linked third party websites, and we provide these links solely for the convenience and information of our visitors.

What is TPF’s Policy on “Do Not Track” Signals and Third-Party Website Tracking Under the California Online Privacy Act (CalOPPA)?

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

We do not engage in the collection of Personal Data over time across third-party websites, and we do not permit third parties to gather information passively on our website for behavioral advertising purposes.

California Privacy Rights

Under California law, a California resident with whom TPF has an established relationship has the right to request certain information with respect to the types of Personal Data TPF has shared with third parties for their direct marketing purposes (if any), and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. In response to a written request, TPF is allowed to provide a cost-free means to opt-out of such sharing.

Since TPF does not provide your Personal Data to third parties for their direct marketing purposes, it is not necessary for us to establish this procedure; however, if you do not want TPF to use your Personal Data to provide information about our programs, please follow the cost-free opt-out procedures in this policy

Can TPF change this privacy policy?

TPF may change this privacy policy at any time without notice. However, if the Privacy Policy changes, we will post an updated version on the Website. The policy revision date will be posted at the bottom of the page.

Last Updated: August 16, 2019