Privacy Statement

1. What This Document Is

This document is a Privacy Policy Statement (“Policy Statement”). It is updated at our discretion from time to time. And by accessing or using our services and resources or by entering into any agreement with the below mentioned entities or departments (us) that either reference or fail to reference this Privacy Policy Statement, you acknowledge either personally or on behalf any organization that you represent (together, “you”) that you have read and understand this Privacy Policy and agree to it completely.

2. Who We Are

The United Pentecostal Church Development Fund, Inc., (“UPCDF”) is one of the independent entities affiliated with the United Pentecostal Church International (“UPCI”) that is managed and administered by The Stewardship Group, a department of the UPCI. The Stewardship Group manages three separate operating entities which are affiliated with UPCDF and share some common control as required by the IRS rules, which are United Insurance Solution, Inc. and United Pentecostal Foundation. While The Stewardship Group is part of the UPCI, it exists solely to provide leased employees and management services for the entities under its management. The UPCDF (i.e. “The Stewardship Group,” “Fund,” “we,” “us,” or “our”) recognizes the importance of keeping information about you secure and confidential. This Privacy Policy describes the information that identifies you or can be used to reasonably identify you (“Personal Information”) collected through our services provided to you via any method of communication including our family of websites which are the following:

• www.upcstewardship.com
• www.upciloanfund.org
• www.unitedpentecostalfoundation.com
• www.unitedinsurancesolutions.org
• www.stewardshipconnect.com

This Privacy Policy also describes the online services we provide (together, the “Services”), and how that Personal Information is used and disclosed. The Fund and its service providers may collect or receive the types of Personal Information described below in connection with your access to and use of the Services. Our websites above may contain links to third-party websites may contain links to or be linked to websites that are not operated, maintained, or controlled by the Fund. The Fund is not responsible for and makes no representations about the privacy policies or practices of any third parties or any third-party websites. This Privacy Policy does not apply to any third-party websites or to any personal or other information that you may provide to third parties other than the specific website addresses listed above. You should reach the applicable privacy policies for each website that you visit. Please note that any investor of UPCDF will receive an Offering Circular or Private Offering Memorandum, and other documents depending upon the jurisdiction of the investor. This Privacy Statement is meant to be read in conjunction with, and notwithstanding those important, controlling documents.

3. Categories of Information We Collect

The Personal Information that we may collect from or about you are as follows:

3.1 Personal Information that you volunteer such as:

• Identifying Information: Name, address, phone number, email address
• Organizational Information: Church name, leadership details, and related organizational data
• Financial Information: Financial statements, banking-related information, or insurance-related data
• Transaction Information: Information related to your requests, applications, or transactions with us
• Other Information: Any information you provide

3.2 Personal Information from Third Parties.

3.3 Personal Information collected from use of our services

For example, IP addresses, data collected by cookies, location data, however, we cannot control third party use of any tracking technologies and we do not honor do not track requests.

We will send our customers an annual Privacy Notice that is compliant with the Gramm-Leach-Bliley Act (GLBA) and subject to the protections and limitations of GLBA, and is fashioned from the safe-harbor disclosure.

4. How We Use & Disclose Personal Information

The Fund will not sell or rent Personal Information. We will use and disclose your Personal Information for the purpose for which it was collected, for example, to provide the Services, to respond to your requests, to administer the Services, to administer and communicate with you in connection with your account (including to process your investment transactions and to provide you with account statements), and to provide you with information and communications that you request. We will use location information to understand where users of our Services are located. We may use Personal Information to notify you of changes made to the Services (for example, changes to this Privacy Policy), and to provide you with promotional materials and other communications as described above. You may opt out of receiving promotional emails from us at any time by following the unsubscribe instructions contained in the applicable email or by contacting us using the contact information provided below under “Contact Us.” ”

We may disclose your Personal Information to our third-party service providers, suppliers, consultants, agents, distributors, representatives, and partners (including Services management and hosting suppliers, identity verification service providers, accounting and customer management software providers, and email service suppliers) that provide data processing services to us (e.g., to support the delivery of, provide functionality on, or help to enhance the security of the Service or our websites, services, or products) or that otherwise process Personal Information for purposes that are described in this Privacy Policy or communicated to you when we collect your Personal Information. Our suppliers are authorized to and may use and disclose Personal Information as necessary for them to provide the applicable services to us and for certain of these providers, as provided by their own privacy policies as noted above. We do not disclose Personal Information with third parties that have products or services that we think may be of interest to you that we do not also either control or have common affiliation with. We may use and disclose Personal Information: to analyze, develop, and improve the content, materials, products, and services that we make available (including the Services); to inform marketing and communication plans and strategies; and to evaluate Services user needs and customize Services content, promotional emails, and your browsing experience. We may also aggregate Personal Information to create aggregate data on Services users that describes users as a group but does not reveal the identity of individual users.

The Fund may use Personal Information and disclose it with third parties to the extent permitted by applicable law if the Fund believes that such action is necessary or appropriate to (1) comply with the law or with any legal process (e.g., a subpoena, court order, or law enforcement request); (2) protect and defend its rights and property or the rights or property of any other person; (3) protect against misuse or unauthorized use of the Services; or (4) protect the personal safety, property or rights of users of the Services or the public, including disclosing information necessary to identify, contact, or bring legal action in the event of a violation of our contracts, terms, or policies.

• United Pentecostal Church International
• The Stewardship Group, a department of the UPCI
• United Insurance Solutions, Inc.
• United Pentecostal Foundation

Your information may be shared with nonaffiliated third parties. However, in no case will any Personal Information be disclosed to nonaffiliated third parties without us first having a written, enforceable agreement guaranteeing the confidentiality of the information by prohibiting the third party or parties from using or disclosing the information for any purpose other than the one for which it was received. These parties are required to maintain the confidentiality of your information and use it only for legitimate business purposes.