Ethic Inc. (“Company,” “Ethic,” “we”, “us” or “our”) is a technology-driven asset manager that offers personalized, values-aligned and tax-smart portfolio construction and management services based on the investment objectives, values, and risk tolerance of its clients. This Privacy Policy describes how Ethic processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website located at www.ethic.com, our web platform, social media pages, marketing activities, email correspondence, live events and other activities described in this Privacy Policy (collectively, the “Service”)).
This Privacy Policy does not apply to information that we process on behalf of our business customers while providing services to them. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that business customer.
Index
● Personal information we collect
● Tracking & Other Technologies
● How we use your personal information
● How we share your personal information
● Your choices
● Other sites and services
● Security
● International data transfer
● Children
● Changes to this Privacy Policy
● California Shine the light
● How to contact us
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
● Business contact data, such as your first and last name, salutation, email address, company mailing address, professional title and company name, and phone number.
● Demographic data, such as your city, state, country of residence, postal code, and age.
● Profile data, such as the username and password that you may set to establish an online account on the Service and any other information that you add to your account profile.
● Financial data, such as your account balances, holdings and transactions, when you contract directly with Ethic as an adviser to manage your assets.
● Communications data based on our exchanges with you, including when you contact us through the Service, social media, communicate with us via chat features, or otherwise.
● Marketing data, such as your responses to our surveys and your preferences for receiving our marketing communications and details about your engagement with them.
● Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:
● Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
● Data providers, such as information services and registered investment advisor databases, such as AdvizorPro.
● Industry Communities, such as the Investment Advisor Association or databases linked to industry conferences.
● Partners, such as marketing partners and event co-sponsors.
● Service providers that provide services on our behalf or help us operate the Service or our business.
● Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
● Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
● Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
● Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Tracking & Other Technologies
Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:
● Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
● Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
● Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
● Chat and other artificial intelligence (“AI”) technologies, such as those provided by our generative AI platform provider, Gemini, that employs cookies and software code to operate the chat and/or user input/prompt features that you can use to communicate with us and/or input your prompts and other data through the app or services. Gemini and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats or within inputs to facilitate the provision of the app or services.
● RB2B tracking technologies. We use third-party technologies provided by RB2B that use cookies, pixels, and similar tools to associate your browsing activity on our website with other personal information that RB2B or its partners may have about you, including your email address. This information may be used to send you communications and marketing. You may opt out of this use of your information by visiting https://app.retention.com/optout. If you are located in the EU/UK or otherwise wish to exercise GDPR-specific opt-out rights, you may visit https://www.rb2b.com/rb2b-gdpr-opt-out.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
● provide the Service;
● enable security features of the Service, such as enabling Single Sign-On;
● establish and maintain your user profile on the Service;
● communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
● communicate with you about events in which you participate; and
● provide support for the Service, and respond to your requests, questions and feedback.
Service personalization, which may include using your personal information to:
● understand your needs and interests;
● personalize your experience with the Service and our Service-related communications; and
● remember your selections and preferences as you navigate webpages.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, provide customer service and to develop new products and services. For example, we use Google’s BigQuery and Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
Marketing and advertising. We and our service providers may collect and use your personal information to send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Events. We may use your personal information we collect at events and conferences to communicate with you about events in which you participate, contact or market to you, and conduct analytics after collecting your personal information at an event.
Compliance and protection. We may use your personal information to:
● comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
● protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
● audit our internal processes for compliance with legal and contractual requirements or our internal policies;
● enforce the terms and conditions that govern the Service; and
● prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business, and to train our AI models and for other machine learning purposes. See the Your choices section, below, for information concerning choices you may have to opt-out of use of your personal information for AI training purposes.
How we share your personal information
We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers, such as Google’s Gemini and Anthropic’s Claude to power certain aspects of the app or services, such as operating the chat and/or user input/prompt features, data analytics and recommendations. To learn more about how Gemini processes your information, please refer to their privacy policy here: https://policies.google.com/privacy. To learn more about how Claude processes your information, please refer to their privacy policy here: https://www.anthropic.com/legal/privacy.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, including other websites and your business associates, e.g., registered investment advisors, advisory firms, wealth management firms, custodians, and technology providers.
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.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Ethic, financing of Ethic, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Ethic as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. For example, if you provide a testimonial that is intended to be public, we may disclose your information to other users and the public.
Your choices
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non marketing emails.
Cookies and other technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser
and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Training data. As set out in the How We Use Personal Information section, we may use your personal information, provided it is aggregated, de-identified and/or anonymized, to train our AI models and for other machine learning purposes. You may opt-out by contacting us.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
California Shine the Light
Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to legal@ethic.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
How to contact us
● Mail: Ethic Inc.
Attn: Legal Department
99 Hudson, 17th Floor, New York, NY 10013
● Web Form: https://www.ethic.com/contact