Ethic Inc. (“Ethic”, “Company”, “we”, “us” and/or “our”) is committed to protecting your privacy.  We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our websites, located at www.ethic.tech and www.ethic.investments (the “Sites”), as well as all related websites, applications, networks and other services provided by us an on which a link to this Privacy Policy is displayed (collectively, together with the Sites, our “Services”).   This Privacy Policy is incorporated into and is subject to the Ethic Terms of Use found here, and applies whether you are using the Sites to evaluate the Services or for educational purposes or as a client with an investment portfolio managed or advised by Ethic.
1. Questions; Contacting Ethic; Reporting Violation
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:

Ethic Inc.
Attn: Doug Scott, CEO
250 West Broadway 5th Floor, New York, NY 10013
privacy@ethicinvesting.com
2. User Consent
By submitting Personal Data through our Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.
3. A Note About Minors
We do not intentionally gather Personal Data from visitors who are under the age of 18.  If a minor under 18 submits Personal Data to Ethic and we learn that the Personal Data is the information of a minor under 18, we will attempt to delete the information as soon as possible.  If you believe that we might have any Personal Data from a minor under 18, please contact us at privacy@ethicinvesting.com.
4. A Note to Users Outside of the United States
If you are a non U.S. user of the Services, by visiting the Services and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy.  In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.  By providing your data, you consent to such transfer.
5. Types of Data We Collect
Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.  “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.  We collect Personal Data and Anonymous Data, as described below.
(a) Information You Provide to Us
We may collect Personal Data from you, such as your first and last name, phone number, e-mail and mailing addresses, professional title, company name, and password when you create an account to log in to our Services (“Account”).

We may collect holdings information provided by you or your advisor;
If you use our Services on your mobile device, we may collect your phone number and the unique device ID number.

If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information.

Our Services let you store preferences like how your content is displayed.  We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.

When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.

Certain services, such as two-factor authentication, may require our collection of your phone number.  We may associate that phone number to your mobile device identification information.

We retain information on your behalf, such as files and messages that you store using your Account.

If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.  

When you publicly post or share content (such as text, images, photographs, messages, comments or other kind of content) on a publicly accessible area of the Service or with other users of the Services, the information contained in your posting will be stored in our servers and other users will be able to see it. The information that you provide in your profile page (“Profile”) will be visible to others.

When you post messages on the message boards of our Sites, the information contained in your posting will be stored on our servers and other users will be able to see it.

When you participate in one of our surveys, we may collect additional profile information.  

We also collect other types of Personal Data that you provide to us voluntarily, including when you answer questions on our Services to determine what kind of portfolio we might recommend to clients, your financial and sustainability goals and objectives, other financial information and other information your provide during the onboarding process, and other requested information if you contact us via e-mail regarding support for the Services.

We may also collect Personal Data at other points in our Services that state that Personal Data is being collected.
(b) Acting as your Authorized Agent
Ethic offers services where Ethic acts as an agent to retrieve your financial account information, such as your account balances and holdings and transactions, and household information, from financial institutions designated by you. By accessing and using the Services you expressly authorize and direct Ethic, on your behalf, to electronically retrieve your account information maintained by third-party financial institutions with which you have a legally binding customer relationship (“Account Information”). Ethic may work with one or more third-party financial service technology providers to access and retrieve your Account Information.
(c) Information Collected via Technology
Information Collected by Our Servers.
To make our Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.  

Log Files
As is true of most websites, we gather certain information automatically and store it in log files.  This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Services, track users’ movements around the Services, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs.  For example, some of the information may be collected so that when you use the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.  Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.

Cookies
Like many online services, we use cookies to collect information.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.    This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.  

How We Respond to Do Not Track Signals
We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on our Services.

Mobile Services
We may also collect non-personal information from your mobile device if you access the Services through your mobile device.  This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, and information about the type of device you use.
 
Analytics Services
In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Services.  This includes third party analytics services (“Analytics Services”), including but not limited to FullStory, that we engage to help analyze how users use the Services, as well as third parties that deliver content or offers.  We may receive reports based on these parties’ use of these tools on an individual or aggregate basis.  We use the information we get from Analytics Services only to improve our Services.  The information generated by the Cookies or other technologies about your use of our Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy.  By using our Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.  For a full list of Analytics Services we use, please contact us at privacy@ethicinvesting.com. For more information on how FullyStory collects and processes data, please visit: https://www.fullstory.com/legal/privacy/.
(d) Information Collected from You About Others
If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party.  We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above.  You or the third party may contact us at privacy@ethicinvesting.com to request the removal of this information from our database.
(e) Information Collected from Third Party Companies
We may receive Personal and/or Anonymous Data about you from our third party partners, including from registered investment advisor databases.  These third party companies may supply us with Personal Data.  We may add this information to the information we have already collected from you via our Services in order to improve the Services we provide.
6. Use of Your Personal Data
(a) General Use
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better.  We use your Personal Data in the following ways:  

· Facilitate the creation of and secure your Account on our network;

· Identify you as a user in our system;

· Provide improved administration of our Services;

· Provide the Services you request;

· Improve the quality of experience when you interact with our Services;

· Send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

· Send you administrative e-mail notifications, such as security or support and maintenance advisories;

· Send text messages to you to provide notifications and authorizations in connection with the Services;

· Make telephone calls to you, from time to time, as part of secondary fraud protection or to solicit your feedback;

· Offer new products or services;

· respond to your inquiries related to employment opportunities or other requests;

· Tell you about blog posts or services that we believe will be of interest to you; and

· Send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Ethic.
(b) Creation of Anonymous Data
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you.  We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve navigation.  We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
7. Disclosure of Your Personal Data
We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
(a) Third Parties Designated by You
When you use the Services, the Personal Data you provide will be shared with the third party that you designate to receive such information, including other websites and your business associates. For example, registered investment advisors, advisory firms, wealth management and technology providers.
(b) Users
We will share your Personal Data with other users solely for the purpose of providing the Services. For example, advisor firms on the Services may have access to information regarding their end-client accounts.
(c) Third Party Service Providers
We may share your Personal Data with our third party service providers to: provide you with our Services; to invoice or process payments; to retrieve your Account Information; database management; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to provide mailing services; and/or to provide other services to Ethic.
(d) Brokerage Partners
We may share the information required to become a Client with select brokerage partners solely for the purpose of allowing our brokerage partner to provide services to you
(e) Affiliates
We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
(f) Corporate Restructuring
We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
(g) Information You Share; Public Profile
When you use our Services, you may choose to post or share certain information with other users. We may display this content on the Services, and once displayed on web pages viewable by other users, that information can be collected and used by others.  We cannot control who reads the information you choose to share or what other users may do with the information that you voluntarily post and/or share. In addition, certain information may be displayed in your Profile and on the Services, such as your name, professional title, company name, and photo.  You may edit such information by going to your Profile settings. Once you have posted information publicly, while you will still be able to edit and delete it on the Services, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others.
(h) Other Disclosures
Regardless of any choices you make regarding your Personal Data (as described below), Ethic may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Ethic; (c) to protect or defend the rights or property of Ethic or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
8. Third Party Websites
Our Services may contain links to third party websites.  When you click on a link to any other website or location, you will leave our Services and go to another site, and another entity may collect Personal Data or Anonymous Data from you.  We have no control over, do not review, and cannot be responsible for, these outside websites or their content.  Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites.  We encourage you to read the privacy policies of every website you visit.  The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
9. Your Choices Regarding Information
You have several choices regarding the use of information on our Service:
(a) Email Communications
We will periodically send you free newsletters and e-mails that directly promote the use of our Services.  When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).  Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
(b) Cookies
If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know by emailing privacy@ethicinvesting.com.
(c) Changing or Deleting Your Personal Data
All users may review, update, correct or delete the Personal Data in their user account by contacting us or editing their profile via the Services.  If you completely delete all of your Personal Data, then your user account may become deactivated.  We will use commercially reasonable efforts to honor your request.  We may retain an archived copy of your records and residual information related to your Account, as well as any data related to your trades, as required by law or for legitimate business purposes.
(d) Declining to Provide Personal Data
You may decline to provide certain Personal Data to Ethic. Declining to provide Personal Data may disqualify you for features of the Services that require certain Personal Data.
10. Other Important Information
(a) Security
Ethic takes reasonable steps to protect your Personal Data from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free so, please take special care in deciding what information you send to us in this manner. In the event of a data breach involving Personal Data you will be notified as soon as reasonably practicable, along with any supervisory authority as required.Ethic takes reasonable steps to protect your Personal Data from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free so, please take special care in deciding what information you send to us in this manner. In the event of a data breach involving Personal Data you will be notified as soon as reasonably practicable, along with any supervisory authority as required.
(b) Advertising
We do not allow third-party advertising on the Services.
11. Changes to This Privacy Policy
This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Services.  Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Services.  These changes will be effective immediately for new users of our Service.  Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address.  In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.  If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us.  Continued use of our Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.