Description of Users and Acceptance of Terms
Information We Collect or Receive
In the course of operating the Platform and providing the Services, we collect or receive the following types of information:
1. Personal Information
When you register to become a Customer, you will be asked to provide us with certain information about you, such as, your name, date of birth, National ID number and scan, citizenship, home address, telephone number, email address, employer name, employment status, job position, whether you are a “politically exposed person,” whether you are a “control person” (pursuant to FINRA Rule 3210), annual Income range, total net worth range, and other information as appropriate for our legitimate business needs (collectively and together with information referenced in Sections 2-6 below, the “Personal Information”). We may also collect Personal Information when you voluntarily provide us with Personal Information as a Visitor, such as when you use our “Contact” form.
2. Nonpublic Personal Information
3. Investment Style Information
4. Card and Bank Information
5. Transaction Information
6. Other Information
We may automatically collect or receive additional information about you, your use of our Platform, your interactions with us and our advertising, as well as information regarding your computer or other devices used to access our Platform (collectively, the “Other Information”). Such Other Information may Include, but is not limited to, the following:
- From Your Activity
- IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
- Browser type and language;
- Referring and exit pages and URLs;
- Date and time; and
- Details regarding your activity on the Platform, such as search queries and other performance and usage data.
- About Your Device
- Type of device;
- Universally Unique Identifier (“UUID”);
- Advertising Identifier (“IDFA” or “AdID”);
- Operating system and version (e.g., iOS, Android or Windows);
- Wireless carrier; and
- Network type (WiFi, 3G, 4G, or LTE).
- From Cookies, Web Beacons, and Other Similar Tracking Techniques
- Third-Party Analytics
Information Collected by or Received from Third-Party Sources
Information Collected by or Through Third-Party Advertising
How the Information is Used and Shared
You authorize us to use the Personal Information, the Third-Party Information, and the Other Information (collectively, the “Information”) to provide and improve our Platform and Services; to help us improve the content and functionality of our Platform and Services; to provide trade recommendations; to advise you about your portfolio; to solicit your feedback; and to inform you about our products and services and those of third parties.
You also authorize us to use and/or share Information as described below.
- We will access, use, and share the Information as required to fulfill our contractual obligations to you or subsequent requests for support by you.
- To track your purchases, match your purchases with the other Information we have about you and provide suggestions to you about potential trade recommendations, saving money, and other financial services and offers that we believe may help you.
- Vested, like many businesses, sometimes hires other companies to perform certain business-related functions on our behalf. Examples of such functions include website hosting, mailing information, maintaining databases, ID verification, processing applications, processing payments and completing transactions. When we employ another company to perform a function of this nature, we only provide it with the information that it needs to perform its specific function. These companies are authorized to use your Information only as necessary to provide these services to us.
- As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Platform of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
- In an ongoing effort to better understand our Customers, the Platform, the Services, and the products and services of Vested, we may analyze certain Information to compile information about our Customer demographics, interests and behaviors and to create data analytics on an aggregate basis. This aggregate information does not identify you personally. We may share this aggregate information with our affiliates, agents, business partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Platform, the Services and our products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
- Vested may disclose your Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Vested, (iii) act in urgent circumstances to protect the financial security of users of the Platform or the public against fraud or other harm, or (iv) protect against legal liability.
- Vested may from time to time enter into agreements with third parties, such as employers or affiliate membership groups, pursuant to which the third-party may pay a portion or all of the advisory fees of its employees or members, and may on occasion make direct or indirect contributions to the Vested account of its employees or members. This is generally implemented by distributed “promotional codes” that are sponsored by the employer or affiliate membership group. If you use the benefit provided by an employer or affiliate group, you consent to additional anonymized reporting with respect to the participation, contribution rates, engagement, etc., of the employees or members, and consent to personalized reporting (i.e., where you may be specifically identified) solely and exclusively to (x) confirm your use of Vested to your employer or affiliate membership group, and (y) if the employer or affiliate membership group makes a contribution to your Vested account, to confirm receipt of the specific amounts contributed. In addition, if the benefit the employer or affiliate group provides includes embedding the Vested experience in a broader experience hosted by the employer or affiliate, by using such benefit you consent to Vested embedding the Vested experience in the hosted experience, and understand that your Personal Information may be shared in order to implement the hosted experience.
- We may share your Information with third parties, including but not limited to third-party market research firms for analysis purposes and to help such third parties generate market research data for us which will not identify you personally. Such third parties will provide us market research data to help us better segment our customer base and understand what products and services would likely work best for our customers.
If you would like to opt-out of Vested’s sharing of your Information with affiliates and third parties, please contact us at firstname.lastname@example.org. We will use your Information for our internal business purposes, including but not limited to, creating user state modeling and comprehensive behavioral profiling.
Sharing of Your Information with Non-affiliated Third Parties
We will not share your Information with non-affiliated third parties that may use your Information to market to you, without obtaining your opt-in consent. For example, we may offer you with a product opportunity that requires us to share your Information with non-affiliated third parties that may use your Information to market to you. We will obtain your opt-in consent to such sharing of your Information when we present you with the terms of such offer.
When you sign up for our Services or newsletter(s), we will send periodic emails to you regarding the Services or to tell you about services we believe will be of interest to you.
If at any time you wish not to receive any future newsletters or marketing communications or you wish to have your name deleted from our mailing lists, please following the unsubscribe instructions included in these emails or contact us at email@example.com. We will use commercially reasonable efforts to process such requests in a timely manner. Note however that as a user of the Services we and/or our custodian(s) will send you administrative and transactional communications that are reasonably necessary to provide the Services, such as billing, brokerage or service notifications and you cannot opt out of receiving such communications.
We may also deliver notifications to your phone or mobile device. You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.
How We Protect Your Information
The security of your information is important to us. When you enter sensitive information in our App, we encrypt the transmission of that information using secure socket layer technology (SSL). We and our custodian also use third-party ID verification to ensure our users’ true identities are validated.
We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email. If you have any questions about security on our website, you can contact us at firstname.lastname@example.org.
Retention of Your Information
We will retain non-public information such as Account Opening Documentation and Trading Activity Information per the US Securities and Exchange Commission (SEC) requirements for books and records retention. Any request to delete such information is not able to be fulfilled until the regulatory retention periods have passed.
Data Deletion Requests
To request deletion of all your personal data, you will need to request to close your account. You can request to close your account by reaching out to the Vested Customer Support team. Note that applicable non-public data will only be deleted once regulatory retention periods have passed (see “Retention of Your Information” above) following account closure.
We do not email you or send you other electronic communications to request nonpublic information or account information (such as username and password). If you receive an unsolicited email or other electronic communication that appears to be from Vested but you suspect it may be from some other source or fraudulent, please email us at email@example.com.
The Platform is not directed to children under 18, and Vested does not knowingly collect or receive Personal Information from children under the age of 18 through the Platform and/or the Services.
Links to Other Websites and Integration of Third-Party Content
Federal Privacy Notice
Vested is required by US federal law to provide consumers with information regarding our collection and sharing of nonpublic personal information.