Last Updated: January 28, 2022
- Provide an updated definition of “personal information” (See Section 2).
- Clarify how we collect, use, disclose and otherwise process personal information in connection with our Site (See Sections 3 – 5).
- Provide additional information about how to control cookies (See Section 3.2).
- Remove inapplicable jurisdiction-specific disclosures.
If you have any questions about these changes, do not hesitate to contact us at email@example.com.
1. Our Commitment to Your Privacy
Calvert Impact Capital, Inc.® ("Calvert", "we" or "us") recognizes the importance of data privacy in today's digital economy. We believe that privacy is a matter of trust, and we are committed to managing personal information lawfully, fairly, and transparently. We want our website visitors, customers, and business partners (collectively, "you" or "your") to understand the ways we collect and use personal information about you.
- Ways we collect your personal information
- Ways we use your personal information
- Ways we share your personal information
- Ways we retain and safeguard your personal information
- Your rights and choices about how we collect, use and share your personal information
2. Policy Scope
3. Ways We Collect Your Personal Data
3.1. In General
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Site and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties.
Personal Information You Provide We collect the following categories of personal information you provide in connection with our Site:
- Contact Information, including your full name, email address, residential address, mailing address, and phone number(s) when you create an account with us.
- Account Information, including your email address, user-created password, date of account activation/deactivation, account status, date of birth, social security number and optional demographics (such as location) when you create an account with us. Account information also includes the following categories of information:
- Professional Information, including your company’s name, address, tax identification number, and proof of a person being an authorized representative when you create an account for an institution.
- Bank Account Information, including your bank or credit union name, routing number, bank account number, and log in credentials when you choose to link a bank account to your account with us in order to invest and/or to receive payments.
- Investment Information, including the date and time of your investment, the details of your investment, your state of residency at time of investment, and the value of principal and accrued and paid interest on your investment.
- Impact Preferences, including our portfolio impact sectors you want to support (for example: environmental sustainability or affordable housing).
- Survey Information, including, from time to time, personal information we collect from you via an online survey. Participation in these surveys is completely voluntary. Information requested may include personal and demographic information. Survey information will be used for purposes of monitoring and improving the Site and/or Calvert services.
- Inquiry Information, such as the content of your email, voicemail, and phone calls with us.
Personal Information Automatically Collected We collect the following categories of personal information automatically when you visit our Site:
- Log File Data, including your internet protocol (IP) address, internet service provider (ISP), mobile carrier, operating system, browser type, browser id, date/time of visit, and pages visited.
- Analytics Data, including the electronic path you take to our Site, through our Site and when exiting our Site, as well as your usage and activity on our Site, such as the links and object you view, click or otherwise interact with.
- Location Data, including your general geographic location based on your IP address or, where permitted, more precise location when accessing our Site through a mobile device.
Personal Information from Other Sources and Third Parties Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, as noted below.
Social Media: If you choose to interact with us on social media, we may collect personal information about you from your social media account that you make public or otherwise make visible to us. We use personal information collected in connection with your social media account to communicate with you, better understand your interests and preferences, and better understand our customer base in the aggregate.
Service Providers: Our service providers, such as payment processors and marketing providers, collect personal information and often share some or all of this information with us. For example, we receive personal information from payment processors to confirm that your investment or payment was completed.
Publicly Available Information: In order to locate account holders, we may collect personal information from publicly available sources, such as government records or public review websites, to supplement the personal information identified above.
3.2. Cookies and Related Technologies
We and our third-party providers may use (i) cookies or small data files that are stored on your computer and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect personal information.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it, (ii) disable existing cookies, or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our Site, as some features and offerings may not work properly or at all. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Please note certain of our third-party providers may directly collect personal information about your online activities over time and across different websites when you use our website for purposes of providing online behavioral or interest-based advertising services to third parties. We support the self-regulatory principles for online behavioral advertising (“Principles”) published by the Digital Advertising Alliance (“DAA”). These Principles allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our advertising partners, please follow the instructions at www.aboutads.info/choices, or www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again. If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at www.aboutads.info/appchoices.
4. Ways We Use Your Personal Information
We use the personal information we collect through our Site to:
- Provide our Site and services to you, including administering our investment program;
- Administer and improve our Site and services, including to test different configurations of our Site, and diagnose errors and problems with our Site;
- Provide you with news about our Site and services, and deliver marketing communications and advertisements based on your interests and interactions with us;
- Incorporate ideas from your responses into our business operations and customer service models;
- Send you our Impact Report or our monthly email update;
- Send you invitations to events and conferences;
- Answer questions you submit to us;
- Communicate with you regarding our Site, services and events;
- Aggregate information we receive from you and third parties to help understand your needs, customize our Site, services and other offerings to you, and provide you better service;
- Conduct research and analytics designed to understand our customer base and improve our Site, services and customer experience;
- Maintain our contact lists, including for customers and business partners;
- Facilitate our day-to-day business operations, such as maintaining accounts and processing transactions;
- Fulfill any other purpose for which you provide Personal Information;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
- Enforce, carry out and comply with our legal and contractual obligations.
If you are an investor in the Community Investment Notes, we may also use your personal information to process your investment application, to maintain your account and to provide updates related to the Community Investment Notes.
If you wish to request that Calvert refrains from using your personal information to send marketing communications to you, please follow any available opt-out instructions in the marketing communications you receive or by submitting your request to Calvert by using the contact information below. Please note we may continue to send you non-marketing communications even after you opt-out.
5. Ways We Share Your Personal Information
5.1. In General
We disclose personal information in the following ways:
- Payment Processors and Online Payment Systems: We share personal information with payment processors, online payment system providers and other billing agents as part of the bank account linking functionality that is part of Calvert's investment platform.
- Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer service experience, maintaining our customer relation management (CRM) platform and facilitating our communications with you, including third parties that provide email services.
- Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Ways We Use Your Personal Information section above. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf. For example, we engage service providers to provide business resilience and disaster recovery, as well as auditing services.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Legal Obligations and Rights: We may also disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims
- to comply with laws or to respond to lawful requests and legal process
- to detect, suppress, or prevent fraud
- to protect the health and safety of us, our customers, or any person
- as otherwise required by applicable law
- Consent: We may disclose personal information about you to certain other third parties with your consent.
Aggregate Information: When Calvert receives demographic information requested during an information request or registration, you have the option not to provide this information. However, we encourage you to do so that we may gain a better understanding of your needs, and so that we may serve you in a more personalized manner. We may also share your information with others in an aggregated or otherwise anonymized form that is not reasonably capable of being linked to you. In certain instances, we may share aggregate information with strategic partners. For example, we may tell a partner that X number of individuals visited a certain area on the Site, or that Y number of men and Z number of women filled out our registration form.
5.2. Opting-Out of Sharing Your Personal Information
You have choices regarding the ways we share your personal data with third parties. If you wish to opt-out, please submit your request to Calvert by using the contact information below.
6. Individuals Under the Age of 13
Our site is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13 through our Site. If an individual is under the age of 13, they should not use our Site. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
7. Data Security
We strive to align our data security practices with industry standards for securely handling, transmitting and storing personal information. In furtherance of our goal, we implement administrative, physical and technical measures designed to safeguard and secure the information we collect in connection with the Site.
Since the Internet is not a completely secure environment, we cannot ensure or warrant the security of any information you transmit to us. Calvert offers no guarantees that information cannot or will not be accessed, disclosed, altered or destroyed by a breach of any of our administrative, physical or technical measures.
8. Third-Party Websites
This Site may contain links to and from other third-party sites. Please be aware that Calvert is not responsible for the privacy practices of these third-party sites. We encourage you to be aware when you leave our Site, and to read the privacy statements of each website that collects your personal data.
9. How to Contact Us
You may contact us directly via post, phone, or email:
Calvert Impact Capital, Inc. 7550 Wisconsin Avenue, 8th Floor Bethesda, MD 20814 800.248.0337 firstname.lastname@example.org