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.
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.
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 [email protected] 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:
- 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.
- 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.
- 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.
- “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.
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
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 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.
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.
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 [email protected] . 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 [email protected] 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
You may request deletion of Personal Information by contacting us at [email protected] 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.
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
We do not allow third-party advertising on our Site.
Social Media and Links to Other Web Sites and Applications: “Linked Third-Party”
Questions and Contacting Us
Second Floor (UnderscoreVC)
45 School St
Boston, MA 02108