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Your Privacy at Vested

Last Updated: October 28, 2019

Your Privacy Matters

Vested’s number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all of 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 non-public personal information and other types of personal information (“Personal Information”).


Introduction

Vested Inc. and its affiliates (“Vested”, “we”, “us” and/or “our”) provide tools and content relating to startup companies (“Service”). Our Service is made available through Vested’s website, vested.co (“Site”). This Privacy Policy describes how Vested treats your Personal Information when you use or evaluate our Site and/or Service or when you apply to and/or become an employee (“Employee”).


For the purpose of this Privacy Policy, a User is an individual who uses our Site to understand or evaluate our Service or who registers to use our Service.


Our Privacy Policy and Terms of Use collectively govern your use or evaluation of our Site and/or Service.


Information Collection

The type of information we collect depends on whether you are a current or former User and/or Employee. We collect Personal Information from you when you voluntarily provide it to us. Examples of instances when we collect Personal Information include:


  • when you answer questions on the Site to determine your employment and compensation history and options.
  • when you register to open an account,
  • when you apply to become or become an Employee.

Wherever Vested collects Personal Information, we endeavor to provide a link to this Privacy Policy and other relevant terms, such as our Terms of Use.


Information We Collect from Users


We collect Personal Information such as name, address, telephone number and other information you may provide, such as your age, compensation, and risk tolerance, which may include your financial goals and objectives, income information and other financial planning information about your household.


We may collect your e-mail address and/or telephone number should you engage with us via our Site or email.



Information We Collect from Employees

Vested collects Personal Information from current, prospective and former Employees, their designated contact in case of a medical emergency, and beneficiaries under any insurance policy (“Employee Personal Information”). The Employee Personal Information we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, social security number, financial information related to credit checks, bank details for payroll, external brokerage account information, holdings and trading activity, information that may be recorded on a CV, resume or other employment application form, contact information in case of an emergency, and beneficiaries under any insurance policy. Additionally, we may collect sensitive Employee Personal Information, such as details of health and disability, including mental health, medical leave, and parental leave.


Information Regarding Children


Due to the nature of our business, Services and benefits are not marketed to minors. Vested does not knowingly solicit Personal Information from children under the age of 18.


If you are under the age of 18, please do not submit any Personal Information to Vested.


If we learn that we have collected Personal Information directly from a minor, we will delete such information from our files.


If a parent or guardian becomes aware that his or her child under the age of 18 has directly provided us with Personal Information without his or her consent, he or she should contact us at support@vested.co and we will delete such information from our files.


Other Ways We Collect Information


Other means by which we collect Personal Information include the following:


  1. Anonymized or aggregated Information. Vested’s Site automatically record certain anonymized or aggregated information about your use or evaluation of our Service. Anonymized or aggregated information is used for a variety of functions, including the measurement of Users’ interest in and use of various portions or features of the Site. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
  2. Cookies and Pixels. Similar to other technology platforms and services, Vested uses cookies, a small piece of computer code that enables our Web servers to “identify” Users, each time an individual initiates a session on our Site. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your own hard drive at any time. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.
  3. Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
  4. Site Activity. Vested may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site.
  5. “Do Not Track” Technology. We do not collect Personal Information about your online activities over time and across different web sites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third-parties to collect Personal Information about your online activities over time and across different web sites or online services.

How we use Information


User Personal Information


We use your Personal Information to help you evaluate our Service, offer you new products or services, and enhance our Service. We may also use your personal information a number of ways, including research, internal analysis, and analytics.



Mobile Computing

Vested provides websites and online resources that are specifically designed to be compatible for use with mobile computing devices. Mobile versions of our website are governed by the provisions hereunder related to the Site and may require that you log in with an account. In such cases, information about the use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download tools, such as an application, widget or other tool, that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Vested to enable you to access your account information and to enable us to track the use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. We may use Personal Information or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.


Employee Personal Information


We acquire, hold, use and process Employee Personal Information for a variety of business purposes including but not limited to:

  • Human Resources administration and communication
  • Payroll and the provision of benefits; compensation, including bonuses and long term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs
  • Workflow management, assigning, managing and administering projects;
  • Performance and employee development management;
  • Organizational development and succession planning;
  • Emergency contacts and services;
  • Processing of employee expenses and travel charges;
  • Monitoring compliance with regulatory requirements.

Information Sharing and Onward Transfer

We will not sell, rent, or trade your Personal Information (whether you are a current or former User and/or Employee) to any nonaffiliated 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, front running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use


Vested may share your Personal Information among affiliated Vested entities in connection with the provision of Services to Users. There are certain circumstances, in which we may share your Personal Information with nonaffiliated third-parties without further disclosure to you. For example, from time-to-time, we hire third-parties to perform certain business and technology related functions (e.g., mailing information, database maintenance and payment processing). In the case we hire a third party to perform a function of this kind, we endeavor to only provide them with the minimum information they need to perform their specific function and to require these third parties to safeguard your information.


No Renting, Selling or Trading Out List


We will never rent, sell or trade your Personal Information to anyone. Ever.


Your Choices and Opting Out

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

You may decline to provide Personal Information to Vested. Declining to provide personal information may disqualify you from using Vested Services, and Site features that require certain Personal Information.


Opting-Out - Obtaining and Withdrawing Consent

Where you have consented to Vested’s use of your Personal Information, you may withdraw that consent at any time and opt out by contacting us by email, phone or physical mail via the contacts indicated under the “Questions and Contacting Us” section below. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.


Prior to disclosing sensitive Personal Information to a third-party or processing sensitive Personal Information for a purpose other than its original purpose, the purposes set forth under this Privacy Policy or the purpose authorized subsequently by you, we will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, we will comply with the law or contract.


We will use Employee Personal Information only for employment-related purposes. If we intend to use this Employee Personal Information for any other purpose, we will provide the Employee with an opportunity to opt-out of such use.


Restricting Communications


Vested may use your Personal Information 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 communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at support@vested.co . Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications.


Accessing Your Personal Information

Users may contact us at support@vested.co to request information about how to access your Personal Information.


  • Vested provides all Users with continuous access via the Site to prompt reporting information about account status, securities positions and balances.
  • Your requests will be processed in line with local laws, including without undue delay and in accordance with any required time frames. Although Vested makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made within one month of the request, a contact point for any further inquiries and any other legally required information. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access or making any changes to your Personal Information.

Retention and Deletion

Vested retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Site or Services or as necessary to fulfill the purpose(s) for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

You may request deletion of Personal Information by contacting us at support@vested.co and providing us enough information to identify your account and prove that you are the owner of the identified account. 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, or in accordance with applicable laws.


Security

Vested takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free therefore, we cannot ensure or warrant the security of any information you transmit to us.


Other Important Information

Advertising

We do not allow third-party advertising on our Site.


Social Media and Links to Other Web Sites and Applications: “Linked Third-Party”

This Privacy Policy and these terms apply only to Vested operated services and applications. Please note that our Sites may contain links to other websites, applications, social media accounts, and information for your convenience that are not operated or controlled by Vested. Vested does not control Linked Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Vested does not endorse or make any representations about Linked Third-Party information. Any Personal Information you choose to give to Linked Third-Parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third- parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.


Changes to this Privacy Policy

We may update this Privacy Policy from time to time as we deem necessary at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.


Vested encourages you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Your continued relationship with Vested after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by us. Each version of this Privacy Policy will be identified on this page by its effective date.


This document constitutes Vested’s complete Privacy Policy for Vested and its affiliates and the Service and Site.


Questions and Contacting Us


If after reviewing this Privacy Policy, you would like to submit a request, opt-out or you have any questions or privacy concerns, please contact us by email at support@vested.co , by phone at 617-237-0350 or via physical mail at:


Vested Inc

Second Floor (UnderscoreVC)

45 School St

Boston, MA 02108