Privacy Policy

Thank you for visiting our website. This Privacy Policy is designed to help you understand Church Development Fund, Inc. dba CDF Capital collects, uses and shares personal information. We value your privacy, and we will not share your personal information with third parties except as described in this Policy without your consent. 

BY USING THIS SITE, YOU AGREE TO BE BOUND BY THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THE POLICY, PLEASE DO NOT USE THIS WEBSITE OR PROVIDE US WITH YOUR INFORMATION.

What this Policy Covers

This Policy applies to our collection, use and sharing of your personal information (a) when you visit our website (the “Site”) or create an online account with us, (b) receive our communications or participate in our online events, and (c) information that we obtain from third parties such as social media sites, service providers, and content publishers.

This Privacy Policy does not apply to any information or websites not owned or operated by us or information collected by us by other means, and additional terms may apply to the information we collect for other purposes. For example, if you engage us to provide investment services, additional terms may apply and will be made available to you at that time. See our Offerings Circular for additional details. 

Personal Information We Collect

This section of our Policy describes the categories of personal information we collect about you and the different ways in which we collect your personal information. 

Information You Give Us. Personal information you may provide through the Site or otherwise communicate to us includes:

  • Contact information. We collect information about you when you provide contact information to us through the Site, including by creating an account or filing out an application. This information may include your name, job title, email address, mailing address, and phone number.
  • Correspondence. We may collect personal information you provide when you request information, respond to questions, or otherwise correspond with us.
  • Investment Information. We may collect investment information from you when you submit an application or form, create an account, or otherwise correspond with us. This information may include your contact information, social security number, date of birth, account details, financial information, beneficiary information and other similar information.
  • Other information. If we collect other information from you that is not specifically listed here, we will only use such information in accordance with this Policy.

Information Automatically Collected. Our servers and third-party service providers may automatically collect Internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with our Site. We collect this information in server logs and by using cookies or similar tracking technologies. See our Cookie Policy, below, for more information.

Sensitive Information. Except as we may collect in the course of your investment relationship with us, we do not collect sensitive personal information about you or make sensitive data inferences about you. 

How We Use Your Personal Information

This section of our Policy describes the different purposes for which we may use the personal information we collect about you and how we retain your personal information. 

To Provide our Services and Communicate With You. We use your contact information and investment information to:

  • provide you with our services;
  • manage your account;
  • process your application and other requests; and
  • respond to your requests, questions, comments, and feedback.

To Improve our Site. We use your cookie information, including Internet or other electronic network activity information, to:

  • provide, maintain, and improve the Site; and
  • personalize your Site experience.

To Send You Communications and Market to You. We may use your contact information and cookie information to send you marketing materials or other communications, but you may opt out of receiving them as described in the Your Rights and Choices section below.

For Compliance, Fraud Prevention and Safety. We may use some or all of your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons.

With Your Consent. In some cases, we may ask for your consent to collect, use or share your personal information. 

What We Don’t Do. We do not sell your personal information to third parties, process your personal information for targeted advertising (sometimes called cross-contextual behavioral advertising), or process your personal information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers. We will not use the personal information we collect about you for materially different, unrelated, or incompatible business purposes without providing you notice.

How We Retain your Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Because retention periods vary depending on the purpose for collection, we use certain categories and criteria to determine how long we keep personal information. Where your personal information is used for more than one purpose, we will retain your information for the longer of those periods. When we no longer require your personal information, we will take steps to delete or de-identify it. If the information cannot be permanently deleted or de-identified (for example when it is stored in our electronic backups), we will take appropriate steps to ensure that it is: (a) not used in connection with any decision involving you; (b) not shared with anyone except when we are legally required to do so; (c) kept secure; and (d) deleted once possible.

How We Share your Personal Information

We do not sell your personal information, but we may share your personal information with third parties for a number of reasons. Specifically, we share your personal information with the following categories of third parties and for the reasons described below:

Service Providers. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. For example, we may disclose personal information about you to third parties to assist us in providing our Website (such as website designers and hosting service providers), servicing your investments with us (such as data processors), marketing on our behalf (such as mailing services and marketing consultants), or conducting our business (such as our accountants, auditors, and attorneys). This information may include your contact information, investment information (including information you submit on an application or form or include in your account), and cookie information. We require any third party that we contract with who receives such information to protect the confidentiality of your information and to use it only for the specific purposes for which the disclosure is made.

Sponsors. When we host an event, we share your registration information (e.g. name, email, and other contact details) with our event sponsors. 

Compliance, Fraud Prevention and Safety. We may disclose some or all of the personal information we have collected about you as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the section “For Compliance, Fraud Prevention and Safety.”

In Connection with Your Investment. We may share your investment information with persons who represent you or your interests, such as the custodian or administrator of your retirement program. We may also 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).

Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including all of the personal information we have collected about you, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.

With Your Consent. We may share your personal information with other parties and for other purposes not described in this Policy with your consent or as otherwise authorized by you.

Cookie Policy

This section of our Policy describes how we and our business partners may collect and store information about you and your use of the Site through cookies and other tracking technologies. 

What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies”. Cookies set by parties other than the website are called “third party cookies”. Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third-party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.

What Cookies and Other Tracking Technologies do We Use? We use several different kinds of cookies on this Site, including strictly necessary cookies, which are cookies that are necessary for the Site to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Site; and functional cookies, which enable the Site to provide enhanced functionality and personalization. In addition to our own cookies, we also collaborate with various third-party service providers who also use cookies to help us optimize our Site and to understand more about the visitors to our Site. Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning. If you sign up to receive our e-mails, we will also use cookies in conjunction with these emails. When your browser downloads any graphic content in the e-mail, we will also place a cookie on your computer that will tell us if you come to our website at a later date.

Google Services. We use Google Analytics and Google Tag Manager to help us gather statistical information about the visitors to our Site and to market our services. This information is collected via cookies and other identifiers that we and third parties place on our site. We and our third-party partners may use this information to gain a better understanding of the users of our Site and to improve our services. To understand how Google collects and processes data, including through the use of cookies and other technologies, please visit https://policies.google.com/technologies/partner-sites. To opt out of the Google Analytics, we encourage you to check out Google Analytics’ currently available opt-outs for the web.

How Can You Disable Cookies and Other Tracking Technology? Depending on the type of browser and device that you use, you may have the ability to control the type of information that these tools use. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. 

Other Important Privacy Information

Third Party Sites and Services. The Site may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.

Security. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the absolute security of your personal information.

International Data Use and Cross-Border Transfers. We are located in the United States and have affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. However, we will handle your personal information in accordance with this Policy regardless of where your personal information is kept. If you reside in non-US jurisdictions, your use of the Site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified in this Policy. If you have questions about cross-border transfers, please contact us as detailed at the end of this Policy.

Verifying, Changing, and Deleting Your Information. If you have registered for an account through our Site, you may be able to access, review and manage many changes to your information via your account, including updating your profile information and changing your communication preferences. If the information you are seeking is not available within your account, you can contact us as detailed below and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information). 

Children. The Site is not intended for use by anyone under the age of 18, nor do we knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, you should not attempt to use the Site or send any information about yourself to us.

Your Rights and Choices 

This section of our Policy describes your choices with respect to the personal information you provide and the marketing communications you may receive. Depending on where you live, some or all of these rights may be available to you. 

Your Rights. You may have certain rights regarding your personal information, including the right to:

    • Opt Out of Communications. You may opt out of email communications by following the opt-out prompt in the email. To opt out of other forms of communication, please contact us as detailed at the end of this Policy.
    • Correct. You may request that we correct inaccurate personal information that we maintain about you.
    • Know/Access. You may have the right to confirm whether we are processing your personal information and to access such personal information, the third parties with which we share your personal information, and, under certain circumstances, to receive a copy of such personal information. However, under some laws, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
    • Delete. You may request that we delete certain personal information we have collected about you. We will try to honor those requests, but there are certain exceptions, such as our legal compliance requirements, that would not allow us to delete your information.
  • Shine the Light. If you are a California resident, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes.

Consequences of Not Providing Personal Information. While you are not required to provide all personal information identified in this Policy to use our Site or receive our services, certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, you may not be able to create an account and we may not be able to respond to your request, consider your application, or provide you with communication that we believe you would find valuable.

Exercising Your Rights. To exercise your rights above, please reach out to us via the contact information at the bottom of this Policy. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising. We may ask for additional information to verify your identity. The information you provide in your request and any follow-up information we ask from you will be used solely to verify your request. After receiving your request, we will use the information you provided to authenticate your identity or your authority as an authorized agent. However, we may ask you to provide additional information if we cannot authenticate your identity or authority based on the information you have provided and the information in our records or inform you if we believe your request is fraudulent. We will not discriminate against you if you choose to exercise your rights.

Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request unless otherwise required by applicable law. Our response will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.

You may have the right to appeal our refusal to take action on a rights request after receiving our decision by contacting us as directed in our response or as detailed at the end of this Policy. We will try to inform you of our decision in writing within 45 days after receipt of your appeal, with a written explanation of our decision. If we need more time, we will contact you with the reason and the extension period. If your appeal is denied or if you have concerns about the results of an appeal, you may contact your state’s attorney general. We will provide their contact information with the results of the appeal. 

If you have any questions or concerns about our privacy practices or information practices, please contact us as detailed at the end of this Policy.

Changes to this Policy 

We reserve the right to modify this Policy at any time. If we make changes to this Policy, we will post them on the Site and indicate the effective date of the change. If we make material changes to this Policy we will notify you by email or through the Site.

Contact Us

For questions or concerns about this Policy, reach out to us at:

CDF Capital

PO Box 19700

Irvine, CA 92623-9700

Telephone: (888) 540-7112

E-mail: info@cdfcapital.org

This Policy was last updated March 31, 2026.