Version 3.0, Last Revised on December 13, 2018, Effective on December 13, 2018
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 firstname.lastname@example.org.
4. A Note to Users Outside of the United States
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
(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 email@example.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
(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.
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
(f) Corporate Restructuring
(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
8. Third Party Websites
9. Your Choices Regarding Information
You have several choices regarding the use of information on our Service:
(a) Email Communications
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 firstname.lastname@example.org.
(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
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.
We do not allow third-party advertising on the Services.
Ethic Inc. is an SEC registered investment advisor. Past performance is no guarantee of future results. Any historical returns, expected returns, or probability projections may not reflect actual future performance. All securities involve risk and may result in loss. We do not provide financial planning services to individual investors.