PRIVACY & DATA SECURITY: We appreciate your interest in us. This statement discloses the current confidentiality and privacy policy for Global Trust Company, (GTC).

Our Commitment to Confidentiality

We recognize that our relationship with you is based on integrity and trust. We take great care to pre serve theconfidential nature of our relationship and our contractual commitments. At the same time, the nature of our business sometimes requires that we collect and share information with others. To help you better understand the steps we take to protect your data, we provide this notice explaining our information practices.

The Information We Collect

This notice applies to information collected or submitted to us. The types of information we typically collect include plan level information received from companies, Plan Sponsors, custodians and service providers. We use this information in carrying out our responsibility as trustee.

Rules and Restrictions

As a non-depository trust company, GTC does not customarily open individual accounts or receive personal information from individual customers. As such, state and federal rules concerning the privacy of personal information are generally inapplicable. However, GTC is typically a fiduciary in its role as trustee of the trusts it manages. As a fiduciary, it is therefore required to maintain the strict confidentiality of all trust account information and data. We share your information with others only as required by law or in order to facilitate a transaction in the routine course of carrying out our responsibility as trustee. Our third party service providers are required by contract to treat any such information or data as carefully and confidentially as we do. We do not sell or rent this information to any other party.

Our Commitment to Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and administrative procedures to safeguard and secure the information we collect. We have also adopted and implemented a comprehensive Written Information Security Program (WISP) in compliance with applicable data security regulations.

Your E-Mail

We welcome your comments or questions and have provided an e-mail reply for that purpose. Please note that your e-mail, like most non-encrypted communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. For that reason, to protect your privacy, please do not use e-mail to communicate information to us that you consider confidential. You may contact us via telephone or fax at the numbers provided below.

Linking to Other Sites

From time to time, this site may provide links to other sites, not owned or controlled by GTC that we think might be useful or of interest to you. We cannot, however, be responsible for the content or privacy practices used by other site owners.


How to Contact Us

Should you have other questions or concerns about this policy, please contact us:

About GTC

GTC (Global Trust Company, Inc.) is a non depository trust company providing trustee services for some of the largest and most complex institutional asset managers and fortune 500 plan sponsors.

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