NOTICE OF PRIVACY POLICY

PITCAIRN

June 1, 2013
Last Modified: March 2014

At Pitcairn, we consider your personal and financial information to be private and confidential; therefore, its safekeeping and proper use are a priority for us. We understand the value you place on security and the privacy of data that identify you and your account. In appreciation of these concerns, we hold our employees to strict adherence to our privacy practices.

To provide services to you, Pitcairn may share information about you both within the Pitcairn organization and outside Pitcairn with other companies as permitted by law. It is important to us that you understand our information safeguards, the types of information we maintain, what portion we share, and under what circumstances.

Note that Pitcairn does not respond to “do not track” signals or other similar mechanisms.

This notice describes the privacy practices of Pitcairn, including Pitcairn Trust Company and its affiliated entities, Pitcairn Company, Pitcairn Financial Group, Inc., Pitcairn Insurance Agency, LLC, Pitcairn Alternative Investment Fund, L.P., Pitcairn Private Equity Fund, L.P., Pitcairn Private Equity Fund II, L.P., and 165 Township Line, L.P. (collectively, “Pitcairn”), for financial products and services provided to individuals.

INFORMATION PITCAIRN COLLECTS
Pitcairn obtains and uses non-public personal information about you to conduct our business and to provide services to you, including:

  • Information we receive from you (which may include, but not be limited to, your name, address, age, social security number, name of beneficiary) on applications and other forms, and surveys, or through your correspondence or communication with us including but not limited to through the mail, by telephone, facsimile or over the Internet
  • Information about your transactions with Pitcairn and with other companies outside Pitcairn where you have authorized Pitcairn to receive such information
  • Information about your family, assets, liabilities, sources and amounts of income, expenses, estate plans, gifts, and other financial matters

In addition to the foregoing, Pitcairn does not collect (or permit third parties to collect) through this website personal information from users through any form of behavioral tracking. Moreover, Pitcairn does not allow other parties to collect personal information about your online activities over time and across different websites when you use our website.

INFORMATION WE SHARE WITHIN PITCAIRN
We may share all of the information we receive about you within Pitcairn, on a need-to-know basis, to service your relationship, and to offer additional products or services, or to determine eligibility for offers of specialized investment products that can be offered only to certain qualified investors.

INFORMATION WE SHARE WITH OTHERS
Pitcairn does not disclose or sell non-public personal client information to anyone, except as permitted by law or with your consent. We are permitted by law to share all the information we collect about you with:

  • Authorized service providers who need this information to perform services for us in connection with your account and Pitcairn’s financial products and services. These services include, but are not limited to, assembling and/or mailing client statements, aggregating client transactions from other financial providers, mailing mutual fund reports, and compiling income tax data for client tax returns
  • Government entities pursuant to regulatory requirements or in response to subpoenas, or to prevent fraud
  • Third parties to enable you to participate in securities class action lawsuits
  • Consultants who need access to data in order to maintain the functionality and integrity of computer systems used by Pitcairn, and our websites

This is not a complete description of the disclosures that we are permitted to make by law, but is meant to give you a general idea of situations in which Pitcairn may disclose information about you or your transactions.

OUR SECURITY PROCEDURES
At Pitcairn, employee access to your information is limited to those with a business need to know such information. We educate our employees on the importance of maintaining the confidentiality of such information, and hold them to strict compliance. In addition, we maintain levels of access, and electronic and procedural security measures.

We do not disclose non-public personal information about former clients except as permitted by law.

This notice updates and replaces any previous notices from Pitcairn about the privacy, security and protection of information. You may have additional privacy protections under state laws. We may amend this privacy notice at any time, and we will inform you of any changes as required by law.

If you have any questions about this notice, please contact your relationship manager.

WEBSITE TERMS OF USE

Welcome to the website of Pitcairn (the “Company”). The following terms and conditions, together with any documents they expressly incorporate by reference (collectively, these “Terms of Use”), govern your access to and use of Pitcairn.com, including any content, functionality, and services offered on or through Pitcairn.com or Client.Pitcairn.com (the “website”), whether as a guest or a registered user of the secure section of the website.

Please read the Terms of Use carefully before you start to use the website. By using the website or by clicking to accept or agree to the Terms of Use when this option is made available to you, you accept and agree to be bound and abide by these Terms of Use and our Privacy Policy, stated above. If you do not want to agree to these Terms of Use or the Privacy Policy, you must not access or use the website.

This website is offered and available to users who are 18 years of age or older. By using this website, you represent and warrant that you are of legal age to form a binding contract with the Company. If you do not meet this requirement, you must not access or use the website.

CHANGES TO THE TERMS OF USE AND/OR PRIVACY POLICY
We may revise and update these Terms of Use and/or Privacy Policy from time to time in our sole discretion. All changes are effective immediately when we post them, and apply to all access to and use of the website thereafter.

It is our policy to post any changes we make to our Terms of Use and/or Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you. The date the Terms of Use and/or Privacy Policy were last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this Terms of Use and Privacy Policy to check for any changes.

However, any changes to the dispute resolution provisions set forth in Governing Law and Jurisdiction will not apply to any disputes for which the parties have actual notice on or prior to the date the change is posted on the website.

Your continued use of the website following the posting of the revised Terms of Use and/or Privacy Policy means that you accept and agree to the changes. You are expected to check this page from time to time/frequently/each time you access this website so you are aware of any changes, as they are binding on you.

ACCESSING THE WEBSITE AND ACCOUNT SECURITY
We reserve the right to withdraw or amend this website, and any service or material we provide on the website, in our sole discretion without notice. We will not be liable if for any reason all or any part of the website is unavailable at any time or for any period. From time to time, we may restrict access to some parts of the website, or the entire website, to users, including registered users of the secure section of the website.

You are responsible for:

  • Making all arrangements necessary for you to have access to the website.
  • Ensuring that all persons who access the website through your Internet connection are aware of these Terms of Use and comply with them.

To access the website or some of the resources it offers, you may be asked to provide certain registration details or other information. It is a condition of your use of the website that all the information you provide on the website is correct, current, and complete. You agree that all information you provide to register with this website or otherwise, including but not limited to through the use of any interactive features on the website, is governed by our Privacy Policy stated above, and you consent to all actions we take with respect to your information consistent with our Privacy Policy.

If you choose, or are provided with, a user name, password, or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any other person or entity. You also acknowledge that your account is personal to you and agree not to provide any other person with access to this website or portions of it using your user name, password or other security information. As a registered user, your unique password will not be stored and therefore, cannot be read by us or anyone else. Your password will be encrypted. Each time you, as a registered user, log in to the secure website, your password will be encrypted again and compared to the one previously encrypted. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing your account from a public or shared computer so that others are not able to view or record your password or other personal information. This website uses additional security measures, including unique logons for registered users, secure sockets layer (SSL) protocol, a certificate server, a firewall, and unique session IDs, valid for the duration of that session and only from that computer being used.

We have the right to disable any user name, password or other identifier, whether chosen by you or provided by us, at any time in our sole discretion for any or no reason, including if, in our opinion, you have violated any provision of these Terms of Use.

INTELLECTUAL PROPERTY RIGHTS
The website and its entire contents, features, and functionality (including but not limited to, all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof), are owned by the Company, its licensors, or other providers of such material and are protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws.

These Terms of Use permit you to use the website for your personal, non-commercial use only. You must not reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store, or transmit any of the material on our website, except as follows:

  • Your computer may temporarily store copies of such materials in RAM incidental to your accessing and viewing those materials
  • You may store files that are automatically cached by your web browser for display enhancement purposes
  • You may print or download one copy of a reasonable number of pages of the website for your own personal, non-commercial use and not for further reproduction, publication, or distribution
  • If we provide desktop, mobile, or other applications for download, you may download a single copy to your computer or mobile device solely for your own personal, non-commercial use, provided you agree to be bound by our end user license agreement for such applications
  • If we provide social media features with certain content, you may take such actions as are enabled by such features

You must not:

  • Modify copies of any materials from this site
  • Use any illustrations, photographs, video or audio sequences, or any graphics separately from the accompanying text
  • Delete or alter any copyright, trademark, or other proprietary rights notices from copies of materials from this site

You must not access or use for any commercial purposes any part of the website or any services or materials available through the website.

If you wish to make any use of material on the website other than that set out in this section, please address your request to the Director of Marketing.

If you print, copy, modify, download, or otherwise use or provide any other person with access to any part of the website in breach of the Terms of Use, your right to use the website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made. No right, title, or interest in or to the website or any content on the website is transferred to you, and all rights not expressly granted are reserved by the Company. Any use of the website not expressly permitted by these Terms of Use is a breach of these Terms of Use and may violate copyright, trademark and other laws.

TRADEMARKS
The Company name, the terms Pitcairn, Pitcairn Family Office, the Company logo, and all related names, logos, product and service names, designs, and slogans are trademarks of the Company or its affiliates or licensors. You must not use such marks without the prior written permission of the Company. All other names, logos, product and service names, designs, and slogans on this website are the trademarks of their respective owners.

PROHIBITED USES
You may use the website only for lawful purposes and in accordance with these Terms of Use. You agree not to use the website:

  • In any way that violates any applicable federal, state, local, or international law or regulation (including, without limitation, any laws regarding the export of data or software to and from the US or other countries)
  • For the purpose of exploiting, harming, or attempting to exploit or harm minors in any way by exposing them to inappropriate content, asking for personally identifiable information or otherwise
  • To transmit, or procure the sending of, any advertising or promotional material without our prior written consent, including any “junk mail”, “chain letter”, or “spam” or any other similar solicitation
  • To impersonate or attempt to impersonate the Company, a Company employee, another user, or any other person or entity (including, without limitation, by using email addresses or screen names associated with any of the foregoing)
  • To engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of the website, or which, as determined by us, may harm the Company or users of the website or expose them to liability

Additionally, you agree not to:

  • Use the website in any manner that could disable, overburden, damage, or impair the site or interfere with any other party’s use of the website, including their ability to engage in real time activities through the website
  • Use any robot, spider, or other automatic device, process, or means to access the website for any purpose, including monitoring or copying any of the material on the website
  • Use any manual process to monitor or copy any of the material on the website or for any other unauthorized purpose without our prior written consent
  • Use any device, software, or routine that interferes with the proper working of the website
  • Introduce any viruses, trojan horses, worms, logic bombs, or other material which is malicious or technologically harmful
  • Attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of the website, the server on which the website is stored, or any server, computer, or database connected to the website
  • Attack the website via a denial-of-service attack or a distributed denial-of-service attack
  • Otherwise attempt to interfere with the proper working of the website.

CHANGES TO THE WEBSITE
We may update the content on this website from time to time, but its content is not necessarily complete or up-to-date. Any of the material on the website may be out of date at any given time, and we are under no obligation to update such material.

INFORMATION ABOUT YOU AND YOUR VISITS TO THE WEBSITE
All information we collect on this website is subject to our Privacy Policy, stated above. By using the website, you consent to all actions taken by us with respect to your information in compliance with the Privacy Policy.

LINKING TO THE WEBSITE AND SOCIAL MEDIA FEATURES
You may link to our homepage, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval, or endorsement on our part without our express written consent.

This website may provide certain social media features that enable you to:

  • Link from your own or certain third-party websites to certain content on this website
  • Send e-mails or other communications with certain content, or links to certain content, on this website
  • Cause limited portions of content on this website to be displayed or appear to be displayed on your own or certain third-party websites

You may use these features solely as they are provided by us and solely with respect to the content they are displayed with and otherwise in accordance with any additional terms and conditions we provide with respect to such features. Subject to the foregoing, you must not:

  • Establish a link from any website that is not owned by you
  • Cause the website or portions of it to be displayed, or appear to be displayed by, for example, framing, deep linking or in-line linking, on any other site
  • Link to any part of the website other than the homepage
  • Otherwise take any action with respect to the materials on this website that is inconsistent with any other provision of these Terms of Use

The website from which you are linking, or on which you make certain content accessible, must comply in all respects with the provisions of these Terms of Use.

You agree to cooperate with us in causing any unauthorized framing or linking immediately to cease. We reserve the right to withdraw linking permission without notice.

We may disable all or any social media features and any links at any time without notice in our discretion.

LINKS FROM THE WEBSITE
If the website contains links to other sites and resources provided by third parties, these links are provided for your convenience only. This includes links contained in advertisements, including banner advertisements and sponsored links. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party websites linked to this website, you do so entirely at your own risk and subject to the terms and conditions of use for such websites.

GEOGRAPHIC RESTRICTIONS
The owner of the website is based in the state of Pennsylvania, in the United States of America. We provide this website for use only by persons located in the United States. We make no claims that the website or any of its content is accessible or appropriate outside of the United States. Access to the website may not be legal by certain persons or in certain countries. If you access the website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

DISCLAIMER OF WARRANTIES
You understand that we cannot and do not guarantee or warrant that files available for downloading from the internet or the website will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our site for any reconstruction of any lost data. WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES, OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA, OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

YOUR USE OF THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER THE COMPANY NOR ANY PERSON ASSOCIATED WITH THE COMPANY MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY, OR AVAILABILITY OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, NEITHER THE COMPANY NOR ANYONE ASSOCIATED WITH THE COMPANY REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT, OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE, OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

THE COMPANY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT, AND FITNESS FOR PARTICULAR PURPOSE.

THE FOREGOING DOES NOT AFFECT ANY WARRANTIES WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

LIMITATION ON LIABILITY
IN NO EVENT WILL THE COMPANY, ITS AFFILIATES, OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS, OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, ANY WEBSITES LINKED TO IT, ANY CONTENT ON THE WEBSITE OR SUCH OTHER WEBSITES, OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR SUCH OTHER WEBSITES, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT OR OTHERWISE, EVEN IF FORESEEABLE.

THE FOREGOING DOES NOT AFFECT ANY LIABILITY WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

INDEMNIFICATION
You agree to defend, indemnify, and hold harmless the Company, its affiliates, licensors, and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to your violation of these Terms of Use or your use of the website, including, but not limited to, your User Contributions, any use of the website’s content, services and products other than as expressly authorized in these Terms of Use or your use of any information obtained from the website.

GOVERNING LAW AND JURISDICTION
All matters relating to the website and these Terms of Use and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the Commonwealth of Pennsylvania without giving effect to any choice or conflict of law provision or rule (whether of the Commonwealth of Pennsylvania or any other jurisdiction).

Any legal suit, action, or proceeding arising out of, or related to, these Terms of Use or the website shall be instituted exclusively in the federal courts of the United States or the courts of the Commonwealth of Pennsylvania in each case located in the City of Philadelphia and County of Philadelphia, although we retain the right to bring any suit, action or proceeding against you for breach of these Terms of Use in your country of residence or any other relevant country. You waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

LIMITATION ON TIME TO FILE CLAIMS
ANY CAUSE OF ACTION OR CLAIM YOU MAY HAVE ARISING OUT OF OR RELATING TO THESE TERMS OF USE OR THE WEBSITE MUST BE COMMENCED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES, OTHERWISE, SUCH CAUSE OF ACTION OR CLAIM IS PERMANENTLY BARRED.

WAIVER AND SEVERABILITY
No waiver by the Company of any term or condition set forth in these Terms of Use shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition, and any failure of the Company to assert a right or provision under these Terms of Use shall not constitute a waiver of such right or provision.

If any provision of these Terms of Use is held by a court or other tribunal of competent jurisdiction to be invalid, illegal or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Terms of Use will continue in full force and effect.

ENTIRE AGREEMENT
The Terms of Use and our Privacy Policy constitute the sole and entire agreement between you and Pitcairn with respect to the website and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, with respect to the website.

YOUR COMMENTS AND CONCERNS
This website is operated by Pitcairn Trust Company with offices at 165 Township Line Road, Suite 3000, Jenkintown, Pennsylvania 19046. All other feedback, comments, requests for technical support, and other communications relating to the website should be directed to the Contact Us page on our website.

Thank you for visiting the website.