Ethic’s number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all the decisions we make, as well as how we gather, use and store any information we acquire from you.We created this Privacy Policy to be as clear and direct as possible about how we gather and use your information. To ensure your privacy we store your personal data (“Personal Data”) on our secure cloud-based servers. The reason we collect Personal Data is to ensure we are in a position to best serve you. We will never rent, sell or trade your personal information to anyone. Ever.
1. Introduction
Ethic Inc. (“Ethic”, “we”, “us” and/or “our”) operates an automated investment service (“Service”). Our Service is made available through our websites (www.ethic.tech and www.ethic.investments). This Privacy Policy describes how Ethic treats your Personal Data when you use or evaluate our service.For the purpose of this policy a User is an entity or an individual who uses our website to evaluate our service, or for educational purposes, and a Client is a company or an individual who signs an agreement with us that entitles the Client to have an investment portfolio managed or advised by Ethic. Our Privacy Policy, Terms of Use and where applicable Client Agreement collectively govern your use or evaluation of our service.
2. Access to the site
The types of information we collect depend on whether you are a User or Client. We collect Personal Data from you when you voluntarily provide information to us. Examples of instances when we collect Personal Data include when you answer questions on our website to determine what kind of portfolio we might recommend if you were to become a Client, when you register to open an account, when you contact our client service organization with questions or when you become a Client. Wherever Ethic collects Personal Data, we make an effort to link to this Privacy Policy and other relevant terms, such as our Terms of Use.
2.1 In general
Ethic’s servers automatically record certain information (“Non-Identifiable” or “Aggregated Data”) about your use or evaluation of our Service. Similar to other technology platforms and services, Ethic records information such as browsing activity, data displayed or clicked on (such as UI elements, and links), and other information (such as browser type, IP address, date and time of access, cookie ID, and referrer URL). Along with cookies, Ethic may also use third-party tracking technology, such as Google Analytics to record similar information regarding you and your activity on the Site.
2.2 Information collection from users
Information Collection from Users. We collect information such as name, telephone number and other optional information you may provide, which may include your financial and sustainability goals and objectives, and other financial information. We may collect your e-mail address and/or telephone number should you opt to engage via our website or email.
2.3 Information collection from clients
Information Collection from Clients. If you choose to become a Client, in addition to the information we collect from you as a User, as described above, we will ask you for additional information during the onboarding process for a Client. This additional information will differ depending on whether the Client is an individual or an entity.
2.4 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, from financial institutions designated. By accessing and using the Ethic 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.

Ethic is not responsible for and cannot guarantee the accuracy or timeliness of Account Information we retrieve on your behalf directly, from third-party technology providers, from third-party financial institutions where your accounts are held, or from third-party market data providers used to provide the Services.
3. Use of information
Ethic stores, processes, and maintains data related to you in order to provide client support, offer new products or services and provide our Service to Clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission and FINRA. You may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Client.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.Ethic may use your Personal Data to communicate with you regarding our Service or to tell you about blog posts or services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications. Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications.
4. Information sharing and onward transfer
We will not sell, rent, or trade your Personal Data with any third parties except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use.There are certain circumstances, outlined below, in which we may share your Personal Data without further disclosure to you. From time-to-time, we hire other companies to perform certain business and technology related functions (e.g. mailing information, database maintenance and payment processing). In the case we hire another company to perform a function of this kind, we only provide them with the minimum information they need to perform their specific function. Ethic maintains strict procedural safeguards that comply with federal standards to guard your Non-Public personal information.Except as required by law or requested by regulatory authorities, Ethic agrees to maintain your non-public Personal Data in strict confidence.
5. Your choices and obligations
You may request to update, access or delete any or all of your personal information by emailing support@ethicinvesting.com and providing us enough information to identify your account and prove that you are the owner of the identified account. We will endeavor to make any update, access or delete request effective as soon as reasonably practicable. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies.You may decline to provide personal information to Ethic. Declining to provide personal information may disqualify you for Ethic services and Site features that require certain personal information.
6. Other important information
TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT SHALL COMPANY (OR OUR SUPPLIERS) BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY LOST PROFITS, LOST DATA, COSTS OF PROCUREMENT OF SUBSTITUTE PRODUCTS, OR ANY INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL OR PUNITIVE DAMAGES ARISING FROM OR RELATING TO THESE TERMS OR YOUR USE OF, OR INABILITY TO USE, THE SITE, EVEN IF COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. ACCESS TO, AND USE OF, THE SITE IS AT YOUR OWN DISCRETION AND RISK, AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR DEVICE OR COMPUTER SYSTEM, OR LOSS OF DATA RESULTING THEREFROM.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, OUR LIABILITY TO YOU FOR ANY DAMAGES ARISING FROM OR RELATED TO THIS AGREEMENT (FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION), WILL AT ALL TIMES BE LIMITED TO A MAXIMUM OF FIFTY US DOLLARS (U.S. $50). THE EXISTENCE OF MORE THAN ONE CLAIM WILL NOT ENLARGE THIS LIMIT. YOU AGREE THAT OUR SUPPLIERS WILL HAVE NO LIABILITY OF ANY KIND ARISING FROM OR RELATING TO THIS AGREEMENT.

SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU.
6.1 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.
6.2 Advertising
We do not allow third-party advertising on our Website.
6.3 Social media and links to other web sites and apps: “Third parties”
This Privacy Policy and these terms apply only to Ethic operated services and applications. This Site may contain links that access other web sites and apps that are not operated or controlled by Ethic. The policies described herein do not apply to Third Party websites or applications.
6.4 Media
Ethic is not to be used by anyone under the age of 18 and, as such does not knowingly collect Personal Data from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Data to Ethic. If a parent or guardian becomes aware that his or her child under the age of 18 has provided us with personally identifiable information without his or her consent, he or she should contact us at support@weareethic.com and we will delete such information from our files.
6.5 Other
This Privacy Policy may change from time to time. We will post any Privacy Policy changes and, if the changes are substantial, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its effective date. This document constitutes Ethic’s complete Privacy Policy for Ethic and the Services.
If you have questions or comments about this Privacy Policy, please email us at support@ethicinvesting.com.