At Greenleaf Trust, our customers' financial security is our mission, and their privacy is our responsibility. We believe that privacy should not be compromised. Yet at the same time, we collect information our customers have chosen to share so that we can offer our trust services in order to accomplish their financial goals. Greenleaf Trust can do both by adhering to the privacy principles that have been adopted, as follows:

1. Recognition and Expectations of Privacy. We recognize that one of our most important assets is our customers' trust. And while information is critical to providing quality service, the safe keeping of customer information is a fundamental responsibility of Greenleaf Trust.
2. Retention and Use of Information. We collect and retain information about customers if it is for a specific business purpose, to understand their financial needs, and/or to assist them in the development and improvement of our products and services. We are also required to comply with certain laws and regulations and will use this information as necessary.
3. Maintenance of Accurate Information. The procedures that are in place are designed and expected to obtain and maintain accurate information about our customers. In the event that any information is found to be incorrect, we will, upon notice, investigate and correct any inaccuracies.
4. Limiting Employee Access to Information. The personal and financial information of our customers is available only to those identifiable employees who have a need to know that information. Those employees are instructed, individually, on the importance of maintaining the confidentiality of this information and are required to maintain this confidentiality through our internal operating procedures.
5. Security Procedure to Protect Information. We have in place security standards and procedures to aid in the prevention of unauthorized access to confidential information about our customer accounts. All of our operational and trust data processing systems are maintained "in-house." All trust statements are produced in-house. Our technology is continuously reviewed and updated to improve the protection of this information and to assure its integrity.
6. Disclosure of Customer Account Information. It is the policy of Grenleaf Trust to not reveal specific information about customer accounts or other personally identifiable data to unaffiliated third parties. The disclosure of specific information about customer accounts or other financial information is made only when:
   1. the customer or the trust document directs that the investment advisory services for the account be provided by a third party investment manager;
   2. a directed-broker has been named;
   3. the customer is a retirement plan, and recordkeeping services for the plan are performed by an unaffiliated third party;
   4. government reporting is prepared by an unaffiliated third party;
   5. the disclosure is required or allowed by law (e.g., exchange of information with reputable reporting agencies, subpoena, investigation of fraudulent activity, regulatory exams, etc.); or
   6. the disclosure is at the customer's request.
   
   
7. Maintaining Privacy in Business Relationships with Outside Third Parties. When Greenleaf Trust conducts business with third parties as noted above, we require the parties to maintain similar standards of conduct regarding the privacy of customer information. This will not be done unless such parties agree to maintain the confidentiality of this information and to abide by applicable law.

Greenleaf Trust recognizes and respects the privacy expectations of our customers. We want our customers to understand our commitment to privacy, and as a result of our commitment, we developed these privacy principles, which are readily available to our customers.