PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy (“Policy”) explains how Frontier Capital Trust, together with its operating affiliates, including Frontier Capital Services LLC (collectively, “FCT,” “we,” “us,” or “our”), collects, uses, safeguards, stores, and discloses information in connection with its Christian Fiduciary Stewardship Program and related administrative, educational, and stewardship-oriented services.

FCT recognizes that the information entrusted to it may include highly sensitive personal, financial, fiduciary, family, and business information. We therefore seek to handle such information in a manner consistent with:

  • lawful privacy and confidentiality principles,

  • prudent fiduciary-style administrative discipline, and

  • the values of stewardship, discretion, accountability, and good faith.

This Policy is intended to provide transparency regarding our information practices. It does not create any fiduciary, attorney–client, or CPA–client relationship, nor does it alter any legal rights or obligations that may arise under separate engagement documents or applicable law.

2. MISSION-ALIGNED DATA STEWARDSHIP

FCT’s services are provided within a broader Christian Fiduciary Stewardship Program, aligned with the educational, charitable, and stewardship-oriented purposes of Father Christ Ministries Trust. As part of that alignment, we seek to treat information not merely as data, but as something entrusted to us for limited and careful use.

Accordingly, we endeavor to collect and use only such information as is reasonably necessary for:

  • stewardship-oriented education,

  • fiduciary administration support,

  • trust accounting administration,

  • governance and recordkeeping support,

  • compliance preparation, and

  • orderly client service.

Any reference in this Policy to mission alignment, stewardship, or charitable/religious purpose is descriptive of our values and program character only, and is not intended as a legal conclusion regarding church status, integrated auxiliary status, or tax-exempt classification.

3. SCOPE OF THIS POLICY

This Policy applies to information collected by FCT through:

  • our website(s);

  • online forms, email correspondence, and scheduling systems;

  • phone calls, virtual meetings, and consultations;

  • client onboarding materials and engagement processes;

  • fiduciary administration and trust accounting support;

  • invoices, payment processing, and related administrative systems;

  • any other interaction in which information is provided to us in connection with our services.

This Policy applies whether you are:

  • a prospective client,

  • a current client,

  • a former client,

  • a family member, trustee, manager, advisor, or representative of a client, or

  • a visitor to our website.

4. INFORMATION WE COLLECT

We may collect and process the following categories of information:

4.1 Identification and Contact Information

  • name

  • mailing address

  • email address

  • telephone number

  • business name and title

  • family office or trust affiliation

4.2 Client and Family Information

  • names of family members, trustees, beneficiaries, managers, and advisors

  • general family structure or succession information

  • charitable and stewardship objectives

  • information relevant to family governance and continuity

4.3 Financial and Fiduciary Information

  • trust and entity structure information

  • business ownership information

  • administrative accounting data

  • trust accounting and ledger records

  • income, principal, and related fiduciary classifications

  • summaries of tax positions or filings provided by the client or the client’s CPA

  • payment and billing records

4.4 Legal and Governance Information

  • copies of trust instruments, amendments, certificates, schedules, resolutions, meeting minutes, and related administrative materials

  • governance records and supporting internal documents

  • information regarding the client’s legal advisors and tax advisors

4.5 Website and Technical Information

When you use our website(s), we may collect:

  • IP address

  • browser type

  • device information

  • usage data

  • pages visited

  • referral information

  • cookies and similar tracking information

4.6 Communications

  • emails

  • letters

  • contact form submissions

  • meeting notes

  • text or chat communications, where applicable

  • file uploads and document submissions

4.7 Special / Sensitive Information

Depending on the engagement, we may receive especially sensitive information, including:

  • account numbers

  • tax return excerpts or summaries

  • confidential financial statements

  • trust-internal family information

  • charitable and religious preferences relevant to stewardship planning

We request that clients provide only such sensitive information as is reasonably necessary for the services being rendered.

5. HOW WE USE INFORMATION

We may use collected information for the following purposes:

5.1 To Provide Services

  • to evaluate, structure, document, and support private fiduciary systems

  • to administer the Christian Fiduciary Stewardship Program

  • to prepare educational and administrative materials

  • to assist with trust accounting administration and record organization

  • to support governance, compliance, and audit-readiness

5.2 To Communicate With You

  • to respond to inquiries

  • to schedule meetings and calls

  • to provide updates and deliverables

  • to issue invoices and administrative notices

  • to coordinate with your approved advisors

5.3 To Maintain Administrative Records

  • to organize client files

  • to maintain governance records

  • to preserve documentation for stewardship and audit-readiness

  • to support long-term continuity of services

5.4 To Improve Our Services

  • to evaluate workflow and administrative systems

  • to improve educational materials, forms, and internal processes

  • to strengthen privacy and data-security practices

5.5 To Comply With Law

  • to comply with legal obligations, lawful requests, court orders, subpoenas, or regulatory requirements

  • to protect our legal rights, defend claims, or prevent misuse

5.6 To Support Mission-Aligned Program Functions

Where appropriate, we may use information to support the broader educational, stewardship, charitable, and administrative mission alignment of the Program, provided that such use remains consistent with client confidentiality and applicable law.

6. LEGAL BASES / BASIS FOR PROCESSING

Depending on the context and jurisdiction, we process information based on one or more of the following:

  • your request for information or services;

  • your consent, where applicable;

  • our legitimate interests in administering our program and services;

  • contractual necessity under engagement documents;

  • compliance with legal obligations;

  • protection of our rights or the rights of others.

If a particular law requires a more specific legal basis or notice, those requirements should be reviewed by counsel and incorporated where applicable.

7. HOW WE SHARE INFORMATION

We do not sell personal information.

We may disclose or share information only as reasonably necessary and appropriate in the following circumstances:

7.1 With Your Authorized Advisors

We may share information with your attorney, CPA, family office representative, trustee, or other advisor where:

  • you request it,

  • your engagement reasonably requires coordination, or

  • the information is necessary for lawful and orderly implementation.

7.2 With Service Providers and Contractors

We may share information with third-party service providers who assist us with:

  • document management

  • hosting and cloud storage

  • payment processing

  • administrative support

  • communication systems

  • cybersecurity and data storage

Such parties are expected to handle information only for the services provided to us and subject to confidentiality and security expectations.

7.3 Within the Program / Mission-Aligned Structure

Because FCT operates in alignment with Father Christ Ministries Trust, information may be used or reviewed internally within that aligned structure to the extent reasonably necessary for administration, stewardship, compliance, and educational purposes.

7.4 For Legal Compliance and Protection

We may disclose information if we believe in good faith that disclosure is necessary to:

  • comply with law, subpoena, court order, or governmental request;

  • protect our rights, safety, or property;

  • investigate fraud, abuse, or misuse;

  • defend against claims.

7.5 Business or Organizational Transition

If FCT or an affiliate undergoes reorganization, restructuring, or transfer of operational functions, information may be transferred as part of that process, subject to confidentiality and continuity protections.

8. PAYMENTS AND FINANCIAL PROCESSING

Payments may be processed through third-party providers such as Stripe or other payment processors. We do not control the independent privacy practices of those processors. Their use of your payment and transaction information is governed by their own privacy policies and terms.

We may maintain internal records relating to:

  • invoices

  • payment status

  • credits or offsets

  • stewardship fee calculations

  • administrative balances

We do not store full payment card information except through properly authorized payment-processing systems.

9. COOKIES, ANALYTICS, AND WEBSITE TECHNOLOGIES

Our website(s) may use cookies, analytics tools, and similar technologies to:

  • improve website functionality;

  • understand visitor traffic and engagement;

  • improve usability and communication.

These technologies may collect technical and usage information. You may manage cookies through your browser settings, although disabling certain cookies may affect website functionality.

If we use analytics or advertising tools that require additional legal disclosures (for example, in certain states or countries), those should be supplemented by counsel as needed.

10. DATA RETENTION

We retain information only for so long as reasonably necessary to:

  • provide services;

  • maintain fiduciary and administrative records;

  • support continuity and stewardship documentation;

  • comply with legal, accounting, tax, or record-retention obligations;

  • defend legal claims or maintain historical governance files.

Unless a longer period is required or justified, fiduciary and accounting records may generally be retained for at least seven (7) years.

We may retain certain records longer where:

  • the nature of the trust or stewardship work requires it;

  • litigation or audit concerns exist;

  • historical continuity of records is important to the Program.

11. DATA SECURITY

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction.

These measures may include:

  • encryption standards (including AES-256 for digital records where appropriate)

  • restricted-access systems

  • password controls

  • backup and integrity checks

  • limited personnel access on a need-to-know basis

  • secure document storage and destruction practices

No method of transmission or storage can be guaranteed to be absolutely secure. Accordingly, while we endeavor to protect information responsibly, we cannot guarantee absolute security.

12. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction and the nature of your relationship with us, you may have certain rights relating to your information, including the right to:

  • request access to information we maintain about you;

  • request correction of inaccurate information;

  • request deletion of information where legally permitted;

  • request restrictions on certain uses of information;

  • withdraw consent where processing is based on consent;

  • request information about our privacy practices.

These rights are not absolute and may be limited by law, privilege, record-retention requirements, or the legitimate administrative needs of the Program.

Requests may be submitted using the contact information below.

13. CHILDREN’S PRIVACY

Our services and website are not directed to children. We do not knowingly solicit or collect personal information directly from children except where family or beneficiary information is provided by an adult client as part of a legitimate fiduciary engagement.

14. INTERNATIONAL USERS

If you access our services from outside the United States, you understand that your information may be transferred to and processed in the United States or other jurisdictions where our systems or service providers operate.

If your circumstances require specific cross-border or jurisdictional privacy protections, such issues should be addressed by counsel and supplemented accordingly.

15. CONFIDENTIALITY OF TRUST, STEWARDSHIP, AND MINISTRY RECORDS

Because our work may involve especially sensitive trust, family, fiduciary, ministry, and stewardship information, we endeavor to treat such records with heightened care. This may include internal restrictions on access, careful file segregation, and long-term retention for continuity and accountability.

However, this Policy is not intended to create an attorney–client, clergy-penitent, fiduciary, or statutory confidentiality privilege where one does not otherwise exist by law.

16. CHANGES TO THIS POLICY

We may revise this Policy from time to time to reflect:

  • changes in our services or operations;

  • changes in law or regulatory expectations;

  • improvements to our privacy and security practices.

When material changes are made, we may update the “Last Updated” date and, where appropriate, provide additional notice.

Continued use of our website or services after such updates may constitute acceptance of the revised Policy, subject to applicable law.

17. CONTACT INFORMATION

Questions, requests, or notices concerning this Privacy Policy may be directed to:

Frontier Capital Trust
[Mailing Address]
[Email Address]
[Phone Number]
[Website URL]

18. IMPORTANT DISCLAIMER

This Privacy Policy is provided to describe our information-handling practices in connection with the Christian Fiduciary Stewardship Program and related services. It does not constitute legal advice, tax advice, or a guarantee of compliance with any particular federal, state, foreign, or ecclesiastical privacy regime. You should consult qualified legal counsel regarding any jurisdiction-specific privacy rights, compliance duties, or exemptions.