Privacy Policy

How We Protect Your Information

Effective Date: August 2025
Last Updated: August 2025

Our Commitment to Privacy

Invest Vegan LLC DBA Ethical Capital (“ECIC,” “we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of our clients’ personal and financial information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage our investment advisory services.

Information We Collect

Personal Information

When you engage our services or visit our website, we may collect:

  • Identity Information: Name, address, phone number, email address, date of birth, Social Security number
  • Financial Information: Investment accounts, income, net worth, investment objectives, risk tolerance
  • Professional Information: Employment details, employer information, professional designations
  • Communication Records: Records of phone calls, emails, and meetings
  • Website Usage: IP address, browser type, pages visited, time spent on site

How We Collect Information

  • Directly from You: Through forms, applications, consultations, and ongoing communications
  • From Third Parties: With your consent, from custodians, other financial advisors, or service providers
  • Automatically: Through website cookies and analytics tools
  • Public Sources: Information available in public records or databases

How We Use Your Information

Primary Uses

  • Investment Management: To provide personalized investment advice and portfolio management services
  • Account Administration: To open accounts, process transactions, and maintain records
  • Communication: To respond to inquiries and provide ongoing service
  • Compliance: To meet regulatory requirements and conduct required reporting
  • Service Improvement: To enhance our services and develop new offerings

Information Sharing and Disclosure

We May Share Information With:

  • Service Providers: Custodians, technology vendors, compliance consultants (under confidentiality agreements)
  • Professional Advisors: Your CPA, attorney, or other advisors (with your consent)
  • Regulatory Authorities: When required by law or regulation
  • Legal Proceedings: When compelled by court order or legal process
  • Business Transfers: In connection with a merger, acquisition, or sale of assets

We Do Not:

  • Sell personal information to third parties
  • Share information for marketing purposes without consent
  • Provide information to unrelated parties for their commercial use
  • Disclose information unless required by law or with your explicit consent

Data Security

Security Measures

We implement comprehensive security measures to protect your information:

  • Encryption: Sensitive data is encrypted in transit and at rest
  • Access Controls: Strict access limitations based on job function and need-to-know
  • Regular Updates: Security systems and software are regularly updated
  • Employee Training: Staff receive ongoing cybersecurity and privacy training
  • Third-Party Assessments: Regular security audits and vulnerability assessments

Data Retention

We retain personal information for as long as necessary to:

  • Provide ongoing advisory services
  • Comply with legal and regulatory requirements
  • Resolve disputes and enforce agreements
  • Generally, records are retained for seven years after account closure or as required by law

Your Rights and Choices

Access and Correction

You have the right to:

  • Access personal information we maintain about you
  • Request correction of inaccurate information
  • Update your contact preferences and communication settings

Marketing Communications

You may:

  • Opt out of marketing emails by clicking unsubscribe links
  • Request removal from mailing lists by contacting us
  • Still receive service-related communications as necessary

Data Portability

Upon reasonable request, we can provide your information in a structured, commonly used format to facilitate transfer to another advisor.

Website Privacy

Cookies and Tracking

Our website uses cookies and similar technologies to:

  • Remember your preferences and settings
  • Analyze website traffic and usage patterns
  • Improve website functionality and user experience
  • Provide personalized content when appropriate

Analytics

We use analytics services (such as Google Analytics) to understand how visitors use our website. These services may collect information about your browsing behavior across multiple websites.

Special Protections for Sensitive Information

Financial Information

We provide additional protections for financial account information and maintain compliance with the Gramm-Leach-Bliley Act and other financial privacy regulations.

Investment Preferences

Information about your ESG preferences and values-based investment criteria is treated as confidential client information subject to our highest privacy standards.

Children’s Privacy

Our services are not directed to individuals under 18 years of age, and we do not knowingly collect personal information from children. If you become aware that a child has provided personal information to us, please contact us immediately.

International Transfers

While we primarily serve U.S. clients, if personal information is transferred internationally, we ensure appropriate safeguards are in place to protect your information.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify clients of material changes through:

  • Email notifications to active clients
  • Prominent notices on our website
  • Updates in regular client communications

State-Specific Privacy Rights

California Residents

Under the California Consumer Privacy Act (CCPA), California residents have additional rights including:

  • Right to know what personal information we collect and how it’s used
  • Right to delete personal information (subject to legal and regulatory requirements)
  • Right to non-discrimination for exercising privacy rights

Other States

We comply with applicable state privacy laws and will honor similar rights where required by law.

Contact Information

Privacy Questions and Requests

For questions about this Privacy Policy or to exercise your privacy rights:

Privacy Officer
Invest Vegan LLC DBA Ethical Capital
90 N 400 E
Provo, UT 84606
Phone: +1 347 625 9000
Email: privacy@ethicic.com

Complaints

If you believe your privacy rights have been violated, you may:

  • Contact us directly using the information above
  • File a complaint with the Utah Division of Securities
  • Contact other applicable regulatory authorities

Regulatory Compliance

This Privacy Policy is designed to comply with:

  • Gramm-Leach-Bliley Act (GLBA)
  • Investment Advisers Act of 1940
  • State securities regulations
  • Applicable federal and state privacy laws

Note: This Privacy Policy applies to information collected through our website and in connection with our investment advisory services. It should be read in conjunction with our client agreements and Form ADV disclosure documents.

For the most current version of this Privacy Policy, please visit our website or contact us directly.