Protecting your privacy is important to CDF CapitalTM, (“CDF”), and its subsidiaries and other affiliates. We want you to understand what information we collect about you and your investments in CDF securities, and how we use that information. The information you provide us is important to our mission and vital to us in serving your needs as an investor in CDF securities.
What Information We Collect
We may collect nonpublic personal information about you from sources such as:
- Directly from you, both orally when we have direct discussions with you and through forms that we ask you to fill out. Sometimes you provide us nonpublic personal information in the form of e-mails, on-line forms, letters, and other documents.
- Through your transactions with us, our affiliates or others.
- Through our Website.
- Through other means.
“Nonpublic personal information” is information about you that we obtain in providing you with, and administering, your investments in CDF securities. For example, nonpublic personal information includes information regarding your investment balance and securities transactions.
What Information We Disclose
We may share nonpublic personal information about you (such as your name, address and church affiliation) with entities related to us by common control or ownership (“affiliates”), such as Provision Ministry Group, Stadia: New Church Strategies and other affiliates (including those existing currently or in the future). For example, we may share nonpublic personal information about you with an affiliate to enable it to contact you seeking support for its mission.
We may also disclose nonpublic personal information about you to persons and organizations not affiliated with us (“third parties”) in the following circumstances:
- We may disclose nonpublic personal information about you to persons who represent you or your interests, such as the custodian or administrator of your retirement program.
- We may disclose nonpublic personal information about you to third parties to assist us in servicing your investments with us (such as data processors and website designers), marketing investments on our behalf (such as mailing services and marketing consultants), or conducting our business (such as our accountants, auditors, and attorneys). We require any third party that we contract with who receives such information to protect the confidentiality of your nonpublic information, and to use it only for the specific purposes for which the disclosure is made.
- We may disclose nonpublic personal information about you to government authorities, in response to subpoenas, and otherwise as may be required by law.
- We may share nonpublic information about you to reduce the risk of fraud, such as in situations where we believe that someone uses or attempts to use our Website for illegal reasons or to commit a fraud.
- We may disclose your name and the fact that you have an investment with us to your church if it has applied or is applying for a loan from us; however, we will not share with your church any specific information about your investment (such as your balance or your transaction activity).
- We may disclose nonpublic personal information about you as otherwise permitted by law.
- We may disclose nonpublic personal information about you as authorized by you.
We do not sell any nonpublic personal information about you to anyone.
Our Security Procedures in General
We take commercially reasonable steps to safeguard nonpublic personal information about you. In doing so, we take commercially reasonable efforts to maintain physical, electronic, and procedural safeguards to prevent improper disclosure and use of your nonpublic personal information. Our employees are allowed to access and use nonpublic personal information about you for business purposes only and are subject to discipline if they violate this Policy.
Privacy on Our Website
If you have enrolled to use our Website to access your investment information, the information you provide us on our Website is subject to this Policy. You may use our Website to access information about your investments in CDF securities, including current balances and detailed history, correct your address, set-up e-mail and mobile alerts for designated balances or transactions, download certain information, and submit a new e-mail address. It also allows you to complete and submit a Purchase application electronically, make payment of your initial investment by electronic funds ACH transfer, request the transfer of additional funds to an existing Certificate that you have purchased, and submit a redemption request.
Information We Collect on Our Website
We only collect personally identifiable information that you voluntarily provide to us on our Website. On some of our web pages, you may be asked for personal information to verify your identity in order to provide you with information about your investments in CDF.
We may keep web logs indicating the IP addresses of those who have visited our Website, but these IP addresses are not linked to any personally identifiable information. We use the IP addresses to analyze and monitor the activities of our Website visitors so that we can improve our Website. We will not try to connect this non-identifiable information with any identifiable information that you may voluntarily provide.
So that we can gain insight on how people are using our website(s), as well as to gain information or perform functions beneficial to users of our website(s) or to our organization, we may track the activity of visitors over time using the website(s) / web server(s), as well as one or more third party service(s). Our website(s) do not currently recognize browser-based "do not track" functionality, but the privacy of our users is important to us and, as such, we do not sell your personally-identifiable information to any third party, nor do we track users' activity across website(s) other than our own.
There may be third party embedded items on our website(s) such as video players, social features, or otherwise. The organizations providing these third party items have the ability to track users that view pages containing those items. If you or a third party has provided personal information to one of these organizations in the past, they may be able to associate your activity with that information. For more details or to find out how to control your privacy settings with a third party provider, please visit their respective website.
Who Should Use Our Website
CDF intends our Website for use only by adults who are 18 years of age or older, and we will not knowingly collect personally identifiable information from anyone under the age of 18. If you are not 18 years of age or older, please do not submit any information to CDF.
Security of Our Website
CDF uses commercially reasonable means to protect the integrity of our Website and the confidentiality of the nonpublic personal information that you provide on our Website. Before sharing any personal information on our Website, you should look for the “lock” icon on the bottom of your browser that appears when you are operating in a secure mode. While we consider online security a priority, we cannot provide absolute assurances against, and will not be liable for, any breaches of confidentiality due to system failures or unauthorized access by third parties.
Links to Other Websites
From time to time, we may include on our Website links to other websites that are not affiliated with CDF. CDF is not responsible for the privacy practices or the content of any website other than that of our Website as operated by CDF. For relevant information about the privacy practices of these other websites, please refer to their privacy policies. This Policy applies solely to information collected by CDF on our Website.
Personal E-mail Safety
Each e-mail message sent to CDF automatically contains the e-mail address of the sender. E-mail addresses are not sold to third parties under any circumstances.
Although we take commercially reasonable efforts to provide you a safe, secure environment while visiting our Website, the nature of e-mail usage today is such that it may not be secure or private in its transmission from you to us. You should take every precaution available to you to assist in maintaining the security on your system, such as:
- Protecting your login ID and password information when using the CDF Website. These are unique to you alone and without them, no one can log into your account. Use passwords that are difficult to guess. Manually enter your login ID and password information each time you log in to our Website. Avoid using software or settings that record your login ID and password information so that you don’t need to enter them each time that you log on. If you suspect your login ID or password has been compromised, change them immediately or contact us for assistance in doing so.
- Protecting your Internet connection by not leaving your computer unattended while logged on to the CDF Website. Always log off when you are finished using the CDF Website.
- Being cautious of fraudulent messages sent from an e-mail address that may pose as CDF inviting you to click on a link to enter your personal login ID and password.
- Installing and frequently updating proven anti-virus, spyware and personal firewall software to protect against a computer virus, spyware and the possibility of infiltration by intruders such as “Trojan Horses,” “Worms,” and the like in order to prevent or limit the possibility of capturing keystrokes, including passwords or other confidential information.
- Only accepting or downloading software from a source that you believe to be trusted and never accepting files or attachments when accessing websites, newsgroups and chat rooms unless you are confident of their authenticity.
- Disabling file sharing on your personal computer in Windows, if you are using a broadband or other high-speed Internet connection. This feature may allow other computers to access your personal computer when the computer is connected to the Internet.
Updating this Policy
We reserve the right to revise this Policy from time to time. If we do change this Policy, we will post the revised version on our Website. Any revision will apply to any information we have about you, whether we collected it before or after the revision. You should check this Policy from time to time. Your use of our Website constitutes your acceptance of this Policy.
We want you to feel comfortable when you provide nonpublic information about you to us. Before providing any nonpublic information about you to us or if you have any questions or concerns about this Policy at any other time please contact us at:
2050 Main Street, Suite 400
PO Box 19700
Irvine, CA 92623-9700
Telephone inquiries: 888.540.7112
Revised November 30, 2016