(NPT) adheres to the following documents that define principles and establish model standards of practice:
NPT’s Privacy Notice
Protecting your privacy is a fundamental component of our service. Since our founding, National Philanthropic Trust has been committed to maintaining the confidentiality, integrity and security of personal information entrusted to us by existing donors, potential donors and their respective advisors. Article 5 of the General Data Protection Regulation (“GDPR”) states that Personal Data must be processed lawfully, fairly and in a transparent manner. Please read the following carefully to understand our views and practices regarding your Personal Data and how we collect, process and destroy it.
For purposes of this Privacy Notice, the following terms will be defined as follows:
- “Personal Data” or “Personal Information” means any information about an individual from which that person can be identified. Personal Data and/or Personal Information does not include data from which you cannot be identified(i.e., anonymous data).
- “Special Categories” means more sensitive personal data which require a higher level of protection, including information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs and health data.
Who we are and how to contact us
National Philanthropic Trust, located at 165 Township Line Road, Suite 1200 Jenkintown, PA 19046, United States, is considered a controller of your Personal Data under GDPR. We determine the purpose for which, and manner in which, any Personal Data is processed as set out in this Notice.
What types of Personal Data do we collect?
Lawful basis for data processing
Where we process your Personal Data as your data controller, we rely on the following (as applicable):
- Consent: We may ask for your consent for our use of your Personal Information for a specific purpose. You always have the right to withdraw your consent.
- Performance of Contract: We will rely on performance of contract as a legal basis when we process your data to perform a contract we have entered into with you or to take steps at your request prior to entering into one.
- Legitimate Interest: We may sometimes rely on our or a third party’s legitimate interest in processing your Personal Data. We will only rely on legitimate interest when we have balanced the legitimate interest against your fundamental rights (see below for additional detail); and
- Legal Obligation: We will process your Personal Data as necessary to comply with legal obligations to which we are subject, including the Internal Revenue Code of 1986, as amended, as it relates to the disclosure of donor names on IRS Form 990 (Return of Organization Exempt from Income Tax).
Purpose of data collected
You may, at times, be asked to supply Personal Information, for example when you inquire about our activities, request information, open a donor-advised fund or other philanthropic account, make a contribution or recommend a grant. NPT also collects data when you visit our website. We use this Personal Information for the following purposes:
- to analyze, evaluate and improve our work and services;
- to provide updates on our work and for marketing purposes;
- to ensure we are not contacting people who have asked us not to contact;
- to satisfy legal obligations that are binding on us;
- for the prevention of fraud or misuse of services;
- for the establishment, defense or enforcement of legal claims;
- to conduct identity, know-your-client, and anti-money-laundering checks;
- to understand more about how the site is used by visitors;
- to provide you with the services, products or information you have requested and communicate with you in general; and
- for administration purposes.
If you do not provide certain Personal Information when requested, we may be limited or unable to provide you with the services you have requested.
NPT may need to share your Personal Information with financial service partners, associated organizations and agents for these purposes. If you supply such information, NPT is legally bound to ensure that such information is only used for the purpose for which it was requested (including the purposes set out in this Notice) and also to ensure that the data is held securely.
Who we share our information with
There may be times when we are required, by law, to pass on some of your Personal Data to:
- Law enforcement agencies; government bodies; tax authorities; courts tribunals and complaints/dispute resolution bodies; or
- Other bodies as required by law or regulation
We also reserve the right to disclose your Personal Information to third parties:
- when you open a donor-advised fund account in one of our private label programs with a financial service partner, we may share your Personal Information with such financial service partner;
- in the event of a business sale, purchase or reorganization, or other business transaction, in which case your Personal Information may form part of the transferred assets;
- with our professional advisors (e.g. lawyers), where necessary to protect our interests; and
- in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.
Otherwise we will not share Personal Information about you with third parties without your consent.
NPT will retain your Personal Data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal or tax requirements, in accordance with the organization’s Data Retention Policy.
Your rights and your personal data
Please be aware that you have the following data protection rights:
- The right to be informed about the Personal Data NPT collects from and processes about you;
- The right to access Personal Data NPT processes about you;
- The right to ratification of your Personal Data where you believe it to be inaccurate;
- The right to erasure of your Personal Data in certain circumstances;
- The right to restrict processing of your Personal Data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your Personal Data; and
- The right not to be subject to automated decision making and profiling.
Please note that these are legal rights subject to exemptions, and that we may ask for additional information to confirm your identity before disclosing Personal Information requested to you.
You can exercise these rights by contacting us using the contact details below.
Where we may seek to further process your Personal Data for reasons other than the original purpose for which it was collected, NPT shall process such data in a manner compatible with the original purpose.
NPT has put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties on a ‘need to know’ basis. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. NPT will only transfer Personal Data to a third party if they agree to comply with those procedures and policies, or put in place adequate measures prior to receiving it. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorized purposes) of the Personal Data.
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.
Special categories of data
We may, in certain cases and only as permitted by law, process Personal Data which are more sensitive in nature – for example, when undertaking a Know Your Client / Anti-Money Laundering (“KYC-AML”) check. While performing our KYC-AML checks, we may come across a past criminal conviction or other similar information about your past.
We may process your Personal Information under the “Legitimate Interests” legal basis. Where this is the case, we will have carried out a “Legitimate Interests Assessment” pursuant to which we weigh your interests and any risk posed to you against our own, and confirm that such processing is a proportionate and appropriate way to further the legitimate interests. Our legitimate interests will include, for example general administrative purposes, purposes related to Human Resources, marketing and/or day-to-day operations.
When sending marketing materials to advisors and/or donors (or other recipients), we may have the option to rely on the advisor’s or donor’s consent, or on Legitimate Interest. We only rely on the Legitimate Interests legal basis for marketing if we have assessed that the information being sent is beneficial to the recipient, and we have weighed our interests against the recipient’s own and there is little to no risk posed, the method and content is non‑intrusive, and the material being sent is something the recipient would usually expect to receive.
In other circumstances, we are required to obtain consent to send marketing materials – for example, where we are sending marketing to individuals by electronic means (such as email and SMS).
You can always opt-out of receiving marketing material from us, by contacting us using the details in this Notice. This does not apply to purely administrative materials that we send to you, and other non-marketing communications.
How to contact us
If you want to review, change or update the Personal Information that you have provided to us; request that you be removed from a mailing list; or address any other privacy concerns you may have, please contact our office toll-free at (888) 878-7900, or by putting your request in writing to National Philanthropic Trust, Data Privacy Team, 165 Township Line Road, Suite 1200, Jenkintown, PA 19046. These requests can also be made via email to: DataPrivacy@NPTrust.org.
Changes to our Privacy Notice
NPT reserves the right to amend this Privacy Notice. Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notice will be provided to you by email.