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 data 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 data about you.
- Ways we collect your personal data
- Ways we use your personal data
- Ways we share your personal data
- Ways we retain and safeguard your personal data
- Your rights and choices about how we collect, use and share your personal data
2. Policy Scope
3. Ways We Collect Your Personal Data
3.1. In General We collect only personal data that you provide to us voluntarily and with your consent. Calvert takes measures to ensure that we collect personal data for specified, explicit and legitimate reasons only – namely, to provide services to you and meet our legal obligations. We also take steps to limit the personal data we collect to only the minimum necessary to carry out our mission.
We may collect your personal data when you:
- Communicate with us via e-mail or other channels;
- When you sign up for our financial reports and newsletters, or;
- When you sign up for an event.
In these instances, we may collect personal data such as your name, e-mail address, postal address, phone and fax number, company name, job title and/or your impact areas of interest (for example: climate change or affordable housing).
If you request materials or invest in our Community Investment Notes®, we may also collect personal data, such as your birthdate, social security number, bank account and optional demographics (occupation, location, etc.).
3.2. Log Files We use log files to record data about each users’ visit to our Site. When you visit the Site, we collect the IP (Internet Protocol) address connected to your computer (or the proxy server you use to access the World Wide Web), your computer operating system, the type of browser you are using, mobile device operating system (if you are accessing the Site using a mobile device), as well as the name of your ISP ("Internet Service Provider") or your mobile carrier. We use this information to analyze overall trends to help improve the Site. We do not share log data with third parties unless required by law to do so.
- Email when logging in; and
- Name, email and interest areas when updating registration.
3.5. Surveys From time to time, we may collect information 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 products and services.
3.6. Your Consent to Our Collection and Subsequent Use By using this Site or otherwise communicating with Calvert electronically, you consent to our collection and subsequent use of your personal data for our legitimate business uses. If you do not consent to such collection or subsequent use of your personal data, please do not use this Site or communicate with Calvert.
4. Ways We Use Your Personal Data
We may use your personal data to communicate with you and provide you investment services. For example, we may use your personal data to:
- Send you our Impact Report or our monthly email update;
- Send you invitations to events and conferences;
- Answer questions you submit to us;
- Maintain our contact list;
- Administer our investment services; and
- Comply with our legal and contractual obligations.
If you are an investor in the Community Investment Notes, we may also use your personal data 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 data to communicate with you, please submit your request to Calvert by using the contact information below.
5. Ways We Share Your Personal Data
5.1. In General We have not and will not sell or lease your personal data to third parties. In the context of the uses of personal data mentioned in the section above, we may share your personal data with third-parties we engage to help provide services to you. These third parties include, but are not limited to, organizations that provide:
- Payment processing for our Community Investment Notes;
- Customer relationship management (CRM) platform;
- Business resilience and disaster recovery;
- User authentication tools and services;
- Auditing platforms and services;
- Correspondence regarding investments; and
- Email and direct marketing tools and services.
Our third-party service providers maintain their own Privacy Policies. We encourage you to visit their websites to learn more.
5.2. Special Circumstances We may also share your personal data in special circumstances, such as:
As required to by law or in response to a subpoena or other government information request;
- If we believe that the disclosure is in the interest of your security or the security of Calvert (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction);
- If we merge with or are acquired by another company, or;
- If we go out of business, enter bankruptcy, or go through some other change of control.
5.3. Sharing Aggregate Information When Calvert requests demographic information requested during an information request or registration, you have the option not to provide this information. 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.
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. We do not disclose information that could be used to uniquely identify you.
5.4. Opting-Out of Sharing Your Personal Data 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. Personal Data Retention
We retain your personal data for as long as you are a business contact to us or as needed to provide you services (including to service any investment you may have in the Community Investment Note). Though you may have the right to request that we delete your personal data under GDPR, Calvert will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
7. Special Notice for Individuals in the European Economic Area (EEA)
If you are resident in the European Union (EU), please be aware that we operate the United States. As such, we may transfer your personal data from the European Economic Area (EEA) to the US to provide you services or otherwise communicate with you. Calvert takes measures to ensure that your personal data is adequately safeguarded when transferred, processed, and stored in the United States or elsewhere. In doing so, we aim to comply with applicable EU data privacy laws and regulations.
By using Calvert's services or otherwise communicating with us electronically, you acknowledge that we may transfer, process or store your personal data outside the EEA, and that we may share your personal data as described in the How We Share Your Personal Data section above.
8. Individual’s Rights Under the General Data Protection Regulation (GDPR)
If you are resident in the European Union (EU), you have certain data privacy rights under the General Data Protection Regulation (GDPR). These rights include:
Access: You have the right to access your personal data held by Calvert.
Correction, Amendment and Removal: You have the right to correct or amend your personal data held by Calvert. You also have a right to request that Calvert deletes certain personal data about you.
Restriction: You have the right to restrict processing of your personal data held by Calvert if you contest the accuracy of your personal data held by Calvert or the lawfulness of Calvert’s processing of your personal data.
Portability: You have the right to receive your personal data held by Calvert in a structured, commonly-used and machine-readable format. You also have the right to transmit your personal data to another organization without hindrance from Calvert.
Objection: You have the right to object, on grounds relating to your particular situation, to Calvert’s processing of personal data about you, unless Calvert demonstrates compelling legitimate grounds for continuing such processing. You also have the right to object to any automated decision-making (such as user profiling) used by Calvert.
Complaints: You have the right to lodge a complaint or concern about our data privacy practices with Calvert directly and/or with an appropriate supervisory authority, as defined by GDPR.
If you wish to exercise any of your rights under GDPR, as described above, please submit your request to Calvert by using the contact information below.
9. California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you wish to exercise your rights under California law, as described above, please submit your request to Calvert by using the contact information below.
10. Individuals Under the Age of 16
Our Site is not intended for individuals under 16 years of age and Calvert does not knowingly collect personal data from individuals under 16 years of age. An individual under age 16 should avoid providing any personal data to the Site without verifiable parental consent. If we learn that we collected or received personal data from an individual under 16 without verified parental consent, we will permanently delete that information.
11. Data Security
We constantly strive to align our data security practices with industry standards for securely handling, transmitting and storing personal data. To prevent unauthorized access, maintain data accuracy and the correct use of information, Calvert implements administrative, physical and technical measures to safeguard and secure the information we collect on this Site. Access to your personal data on the Site is password-protected and the Site utilizes industry-accepted encryption technologies and strengths to reduce the risk that others can view information passing between our Site and your browser.
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.
12. Notification in Event of Data Breach
Calvert is obligated by international, federal and state laws and regulations to notify individuals in the event of a breach of personal data. We will promptly notify those individuals whose personal data has been compromised, in accordance with notification procedures defined in our internal policies, and as required by applicable law.
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.
16. How to Contact Us
You may contact us directly via post, phone, or email:
Calvert Impact Capital, Inc.
7315 Wisconsin Avenue, Suite 1000W
Bethesda, MD 20814
If you request to opt-out, there will be a 30-day period before such opt-out will take effect.