Privacy Policy

As the custodian of our clients' data, we are committed to protecting the personal information of our participants and institutional clients. This Policy applies to any information you provide to Wespath through its website and mobile applications (collectively, "websites"), as well any information we collect from other sources. This Policy is a statement of our practices and of your rights regarding your information.

Throughout this website, "Wespath" refers to the General Board of Pension and Health Benefits of The United Methodist Church, Incorporated in Illinois and its affiliate the UMC Benefit Board Inc.

By accessing or using our websites, using our services, or contacting us, you acknowledge that you have read, understood, and agree to the practices as described in this Privacy Policy.

Information Collected by Wespath

Wespath gathers the following information about users:

1. Information provided by clients and potential clients to transact business. Information that clients and potential clients provide in order to create accounts, consume services, or generally transact business with Wespath including but not limited to: communicating with Wespath via online or paper forms, emails, websites or verbally when contacting our organization via the telephone.
2. Information that users provide through optional, voluntary submissions. These are voluntary submissions including but not limited to: communicating with Wespath via online forms, requesting materials that require mailing, receiving any electronic newsletters, and from participation in online polls and surveys.
3. Information Wespath gathers through aggregated tracking information derived mainly by tallying page views throughout the website(s). This information allows us to better understand our audience's interests and thus tailor our content to readers' needs. Wespath does not divulge any information gathered from our websites about users to a third party except as described below.
4. Information Wespath gathers when you interact with your e-mails. We may use a third party service to track when you open and interact with our e-mails, including when you click on links within our e-mails.
5. Information Wespath gathers through its mobile applications. Wespath gathers information about our mobile device as well as your use of the mobile application.
6. Information Wespath gathers from third party sources. Wespath may collect information from third party sources.

Service Providers

Wespath uses other companies, agents or contractors ("Service Providers") to enhance security and limit fraud in connection with our services and participants' use of the website. In the course of providing such services, these Service Providers may have access to your personal or other information including but not limited to device IDs or unique identifiers, information to facilitate payment transactions, device and software characteristics (e.g., type and configuration), connection information, statistics on page views, referral URLs, ad data, IP address, and standard web log information. We do not authorize them to use or disclose participant personal information except in connection with providing their services.

You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to us or our service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud.

Cookies

We may place small text files called a "cookies" in the browser files of your computer. Cookies help us provide some website functionality, provide analytical data on website use, and enable us to relate your use of this website to information that you have specifically and knowingly provided. A cookie cannot read data off your hard drive or read cookie files created by other websites. Wespath may use cookies to track traffic patterns or provide enhanced functionality to the Website. Cookies we may use include, but are not limited to:

• Google Analytics and DoubleClick, and
• Cookies Generally.

Google Analytics and DoubleClick

We use Google Analytics to recognize you and link the devices you use when you visit our website or otherwise engage with us. Google Analytics allows us to better understand how our users interact with our website. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website "How Google uses data when you use our partners' websites or apps" here. You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Ad-On here. You can find Google's Privacy Policy here.

Third-party ad networks, including Google, use cookies (such as the DoubleClick cookie) to serve ads based on your past visits to the Website. For more information about how Google Ads uses cookies and other technologies to personalize ads, click here. Google's ability to use and share information collected by Google Ads is restricted by Google's Terms of Service and Privacy Policy. If you would like to learn more about how to manage your Google Ad Settings to opt-out of receiving personalized ads served by Google, click here. We also use the DoubleClick cookies and/or pixels in connection with Google Ads. Click here if you would like to learn more about how you can install a browser plugin to maintain your preference to opt out of personalized ads from Google, even if you've cleared your cookies.

Cookies Generally

You can manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by utilizing the choices available at http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices. For E.U. specific information, please visit http://www.youronlinechoices.eu/.

For information about managing cookies, please visit www.allaboutcookies.org. You can refuse cookies by turning them off in your browser. If you've set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. You do not need to have cookies turned on to use the website. However, you may need cookies to utilize certain functions within the website. For browser-specific information on how to adjust cookie configurations on the following browsers, please click on the relevant link below:

• Internet Explorer
• Firefox
• Chrome
• Safari - OSX/Mac OS, iOS

Please keep in mind, that we use browser cookies to improve the functionality of the website and to enhance your experience on Wespath.org. Therefore, changing your browser or device settings to refuse, disable or delete cookies may impact your use of some of the features or services on our website as they may not function properly without cookies.

Disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you previously set, in which case you would have to revisit the applicable pages and renew your opt-out after clearing cookies. Please also keep in mind that browser cookie management tools will not remove flash cookies or prevent other automatic collection methods from functioning.

Cookies on Mobile Devices

For mobile users, you also have numerous controls in your Operating System that enable you to choose whether to allow cookies. For some information on controlling your mobile choices, click here. We do not guarantee that all of the third parties we work with will honor the elections you make using any of these options.

E-mail Choices

Please note that you may not opt out of receiving administrative and transactional communications, legal notices, e-mails about changes to our terms, policies or business practices.

Do Not Track

Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track ("DNT") signals, we do not respond to them at this time.

Governing Law

This privacy policy forms part of our website Terms and Conditions, and as such shall be governed by and construed in accordance with the laws of the State of Illinois.

What Wespath Does about Children Visiting This Website

We will not knowingly collect information from website visitors under the age of 16 years.

How long do we retain your personal information?

We will keep your personal information for the period necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is permitted or required by law.

In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

How secure is my information?

Wespath has implemented reasonable physical, technical, and administrative security standards to protect personal information from loss, misuse, unauthorized access, alteration, or destruction. Although we take reasonable steps to safeguard personal information, no practices are 100% secure, and we do not guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. You must protect against unauthorized access to your computer and important information. We strongly recommend that you log off each time you finish using a shared computer and do not save passwords in Web browsers

Links to third-party websites

Our website provides links to third-party websites that we do not operate, control or maintain. The third-parties operating those websites have their own privacy practices and policies, and we are not responsible for their actions. For example, our website links to the EY Navigate website maintained by Ernst & Young. Its Privacy Policy may be found here. We urge you to read the privacy policies of all third-party websites and third-party advertisers to learn more about their privacy practices and policies.

Notice to California Customers – Your California Privacy Rights

Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of personal information to third parties for the third parties' direct marketing purposes, if any.

To make such a request, send an e-mail with the subject heading "California Privacy Rights" to [email protected] or write to us by post at: Wespath Benefits and Investments, 1901 Chestnut Ave., Glenview, IL 60025. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

European Union Users

Controllers of Personal Data
Wespath Benefits and Investments, 1901 Chestnut Ave., Glenview, IL 60025, is the data controller of the personal data processed through the website.

Legal Bases for Processing Personal Data
If you are an individual located in the European Union (EU), we collect and process personal data about you where we have a legal basis for doing so under applicable EU laws. This means we collect and process your data only when:

• It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving our website, and increasing the security of the website and network infrastructure;
• You have consented to this collection and processing for a specific purpose;
• It is necessary to fulfil our contractual obligations; or
• It is necessary to comply with a legal obligation.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Some examples of where we rely on your consent to process your personal data include sending you our newsletter and marketing e-mails. If you wish to withdraw your consent, please contact us at [email protected].

Some examples of our legitimate interests and the personal data being processed include:

• Website and network security;
• Customer support;
• Fraud prevention; or
• Improving our website.

Where we rely on our legitimate interests to process your personal data, you may have the right to object. More information on exercising this right can be found in the Individual Rights section below.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at [email protected].

Individual Rights
If you are located in the EU, you have certain rights under EU data protection law with respect to your personal data, including the right to request access to, correct, and delete your personal data. You may also have the right to receive a copy of your personal data in a commonly used and machine-readable format, and to transmit such data to another controller. You also may object to processing of your personal data, or ask that we restrict the processing of your personal data in certain instances.

To request deletion of, access to, or to make changes to your personal data, or to otherwise any of the rights in this section, please contact us at [email protected]. If you delete or limit the use of your personal data, or if you transmit your personal data to another controller, you may not be able to use all of our website's functionalities or services.

Transfers, Storage, and Processing
Our website is operated from and hosted on servers located in the United States. If you access and use our website from a location outside of the United States, any personal data you provide to us or that is otherwise collected may be transferred to and processed in the United States or any other jurisdiction in our sole discretion. Users of our website should be aware that the laws that apply to the use and protection of personal data in the United States or other countries or jurisdictions to which we transfer, or in which we process, personal data may differ from those of your country of residence. Users who access or use our website from jurisdictions outside of the United States do so at their own choice and risk and are solely responsible for compliance with local law. While we take steps to safeguard your personal data, the United States has NOT been deemed by the European Commission to ensure an adequate level of protection for personal data. Accordingly, the level of protection provided in the United States or other non-EU countries and jurisdictions from which you may access our website may not be as stringent as that under EU data protection standards or the data protection laws of some other countries, possibly including your home jurisdiction.

By consenting to personal data transfers upon account sign up, you consent to allow your personal data to be transferred across borders to the United States or to other countries or jurisdictions in which Wespath or its third-party associates may process personal data.

If you are a resident of the EU and your inquiry with us has not been satisfactorily addressed, or if you believe we are processing your personal data not in accordance with the law or this Privacy Policy, you may file a complaint with the supervisory authority in your country of residence.

Policy Updates

Please note that this Privacy Policy may change from time to time. We will post any changes to this Privacy Policy on this page. If we make material changes to this Privacy Policy, we may notify you of those changes by additional means, for example, by posting a notice on our website or sending you notification of the revised policy by e-mail, if you have provided your e-mail address to us.

Questions About Our Privacy Policy

If you have any questions about this privacy policy or concerns about the way Wespath uses personal data, please contact us by calling 1-800-851-2201 or using our online contact form.

Effective Date

This Privacy Policy is effective as of April 29, 2021.