Privacy Policy

This policy applies to the collection, maintenance and use of all client and client family non-public financial and personal information. Such information includes:

• Individual identifying information such as dates of birth, social security numbers, addresses, telephone numbers, driver’s license information, and other contact details;

• Information relevant to households and expenses, such as property taxes, credit card statements, and travel expenses;

• Information about investments including asset allocation, performance, transactions, and risk profiles;

• Tax returns and tax-related information;

• Information particular to trusts, including distributions;

• Estate planning documents such as wills, health care proxies, and powers of attorney;

• Total net worth information including liabilities and any assets managed outside of Market Street Trust Company;

• Insurance coverage and related information;

• Information regarding charitable giving and family foundations;  

• Information regarding family governance and dynamics related to wealth management and financial education;

• Information about medical/health information, and/or health insurance coverage; and

• Lists and contact details of service providers such as attorneys, accountants, household employees, real estate agents, and any outside investment advisors.

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Protecting client financial and other personal information is of the utmost importance to Market Street Trust Company. Accordingly, we take substantial steps to safeguard the confidentiality, integrity, and security of client information, both physically and electronically, including:

• Password protecting and otherwise safeguarding our servers, computers, databases, and other software and hardware containing client information;  

• Subjecting certain information, such as fiduciary information, to more restrictive sharing limitations;  

• Striving to keep client information accurate and up-to-date;  

• Maintaining policies and procedures in support of the Market Street Trust Company Privacy Policy;  

• Requiring all Market Street Trust Company employees and third-party vendors with access to financial or personal information to enter into written confidentiality agreements;

• Advising all Market Street Trust Company employees of their obligations relating to client privacy, including proper maintenance and disposal of written documents and electronic data;  

• Requiring employees to report any possible unauthorized disclosure or access immediately; and  

• Promptly investigating and redressing any violation of this Policy.

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WITH CLIENT CONSENT

Other than as described in this Policy, we do not share client financial and personal information outside of Market Street Trust Company unless express permission has been granted by the client. Even in this circumstance, information is shared only to the extent necessary to coordinate the services requested on the client’s behalf (such as legal or tax advisory services.

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WITH CERTAIN SERVICE PROVIDERS

Market Street Trust Company engages with outside service providers to assist in day-to-day business operations. During the course of such engagements, we may provide client financial and personal information to service providers who need such information in order to perform certain services (such as financial auditing) or install certain products (such as accounting software). Even then, all service providers with access to such information are supervised and are required to enter into written confidentiality agreements that restrict their use or disclosure of such information.

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IN A FORMAT THAT DOES NOT PERSONALLY IDENTIFY CLIENTS

We may report client financial and other personal information in an aggregate or grouped form without identifying clients personally, such as to the Market Street Trust Company Board of Directors or to third parties. For example, we may report Market Street Trust Company aggregate investment performance for business development purposes or for industry research purposes.

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OTHERWISE AS PERMITTED OR REQUIRED BY LAW

We may also disclose client financial and other personal information as permitted or required by law, such as in the case of fraud prevention or investigation.

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Market Street Trust Company is unique in that, as a family office, we may provide services not only to an individual client (the owner of the account) but also to that client’s spouse, minor or adult children, and extended family members. These services may be provided to a client’s family members either as clients themselves or as beneficiaries of trusts, borrowers on intra-family and/or trust loans, board members on family foundations, etc. This Policy applies regardless of familial relationships. No individual is privileged to learn the financial and personal information of an adult family member unless the latter has first agreed to share such information or as applicable by virtue of a trust or other agreement.

Clients who would like to ensure that their financial and personal information are shared with certain family members should contact their Relationship Manager to discuss this arrangement further.

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We also ask that our clients do their part to protect their own financial and personal information against disclosure and unauthorized use. This includes but is not limited to taking the following precautions:

• Protecting communications to and from Market Street Trust Company that contain account information or other financial and personal information, including the use of personal log-in information and passwords to access accounts;

• Encrypting emails and attachments sent to Market Street Trust Company;

• Periodically changing passwords;

• Not responding to unsolicited e-mails and phone calls requesting financial and/or personal information;

• Refraining from carrying social security cards or numbers;

• Shredding documents containing financial and personal information or other sensitive data;  

• Reviewing credit reports periodically and reporting suspected identity theft immediately to the police, the Federal Trade Commission, consumer reporting companies, and relevant banks and credit card companies; and

• Using social media with extreme caution and refraining from posting personal or financial data.

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