Advicent is now part of InvestCloud.

Privacy Policy

Privacy Policy

1. InvestCloud’s Commitment To Privacy

InvestCloud, Inc. and its affiliates (collectively, “InvestCloud”, “we”, “us”, or “our”) are strongly committed to protecting the privacy of your information. We are a design and software engineering company, specializing in solutions for the financial industry. In the normal course of our business activities, we act as “data processor” or “service provider” on behalf of our clients (as these terms are defined under applicable law). Such activities fall outside the scope of this “Privacy Notice”. Please read this Privacy Notice carefully to understand the limited circumstances in which it may apply such as: visiting our website or offices; using our products, services, platforms, tools or applications as one of our clients; participating in our events or training; or requesting or receiving information from us. For more information see Section 3., “Processing Activities Covered by this Privacy Notice”.

The objective of this Privacy Notice is to inform you how InvestCloud collects, uses, and discloses your personal data and the rights and choices you may have regarding personal data. For purposes of this Privacy Notice, personal data means any information that relates to an identifiable individual.

2. Scope

InvestCloud, Inc. and its affiliates are responsible for processing your personal data described in this Privacy Notice.

This Privacy Notice applies to personal data collected by us, or provided by you on the InvestCloud websites, mobile applications, social media pages that link to this Privacy Notice; during your interactions with InvestCloud regarding recruitment, training, publications, meetings, and events; and in the context of other sales and marketing activities.

This Privacy Notice does not apply to InvestCloud’s processing of the personal data of its personnel, such as employees and contractors.

This Privacy Notice does not apply to personal data we process in the role of a “data processor” or “service provider” on behalf of our clients or customers, including where we offer to our clients or customers various cloud products and services through which our clients or customers (or their affiliates) collect, use, share or process personal data using our cloud products and services.

We are not responsible for the privacy or data security practices of our clients or customers, which may differ from those detailed in this Privacy Notice.

We may alter this Privacy Notice as needed to abide by local laws or regulations around the world, such as by providing supplemental information in certain countries. If we make material changes to the way in which we use personal data we collect, we will use reasonable efforts to notify you and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not access or continue to use our websites, mobile applications, social media pages, or other tools or services.

3. Processing Activities Covered by this Privacy Notice

When you provide your personal data to us during the following activities, this Privacy Notice applies:

 Visiting and using our websites, such as InvestCloud.com, and our software applications, or social media pages that link to this Privacy Notice;

 Delivering functionality on our websites for technical management;

 Visiting our offices;

 Applying to work with us;

 Requesting or receiving communications from us, including emails, phone calls, texts or fax; or

 Participating in or registering for our events, including any training.

4. The Personal Data InvestCloud Collects

Information that we collect directly from individuals

We may collect personal data directly from individuals and the parties with which we do business, including prospects. These may include parties that interact with us directly (such as job applicants or prospective clients), parties to which we provide products or services (such as clients or customers), and parties that provide services to us (such as vendors or service providers).

The type of personal data we may collect directly includes contact information, professional or employment-related information, commercial information and related payment account details, visual information, identifiers, and internet activity information. Consider the following situations to understand when we may collect personal data from you:

 Interacting with us by using our websites or social media; general correspondence; registering for an event, downloading or receiving publications or content, marketing (such as receiving marketing communications and details about how you engage with our marketing communications). During interactions, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, or email address.

 Interacting with a third-party platform that provides us with information about our pages on those platforms or your interactions with them.

 Purchasing our products or services may involve the provision of demographic details, such as date of birth, country of citizenship and/or country of residence; information about individuals’ affiliation with a legal entity; government-issued identification

numbers (to the extent permitted under applicable law); and/or financial account information, such as bank account details.

 Applying to work with us, for example providing professional credentials and skills, educational and work history, and other related information.

 Visiting our offices, which may require registration as a visitor and the provision of your name, email address, company name and/or time and date of arrival.

If you provide us or our service providers with any personal data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that any such personal data may be used in accordance with this Privacy Notice.

Information that we collect from other sources

We may also receive information about you from other sources including contact information, professional or employment-related information, commercial information, visual information, identifiers, and internet activity information. For example, our clients or service providers may provide us with information about individuals when using our products or services and/or we may reference publicly available information to verify or enhance our records, identify new customers, and improve advertising to provide services that may be of interest to you. Consider the following situations to understand when we may receive personal data about you:

 Our clients, service providers, or third-parties may send us personal data such as business contact information provided to us in the context of our contractual relationships with them;

 Recruiters may send us information about potential job candidates;

 Where our technology is incorporated into a client’s mobile application or website, we also may automatically collect certain information of the type described in the section below titled “Information collected via automated means.”

Information collected via automated means

Like many other web sites, the InvestCloud web site uses cookies and similar technologies such as tags, pixels, web beacons, and JavaScript, alone or in conjunction with cookies (which we will collectively refer to as “Cookies” or “automated means”), to gather information about the use of our websites and how people interact with our emails. The information gathered may include your computer or mobile device identifier, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on our website.

5. Cookies

When you interact with our online services, or open emails we send you, we obtain certain information using “automated means”, such as Cookies. A cookie is a small file downloaded onto a device such as a computer or mobile device when you access our website and subsequently read as you visit our website. To manage your cookies preferences you may adjust your browser’s cookie settings or use the tab on the banner at the bottom of our InvestCloud.com website. Please note that without cookies all of the features of our online services may not work properly. If you reject cookies, only essential cookies will only be used. No personal data will be stored.

For more information about cookies or local storage, including how to see what cookies have been set and how to manage, block and delete them, see: http://www.allaboutcookies.org/.

Types of Cookies we use

We use both session-based and persistent cookies on our website.

We use session-based cookies to:

 Help us maintain security and authenticate your details while you use the website as you navigate from page to page. This enables you to avoid having to re-enter your details each time you enter a new page.

 Remember how you have customized your use of our site, such as session activity for timeout and time zone preferences, etc.

Session-based cookies expire once you close your web browser. They exist only during a single session.

We use persistent cookies to:

 Help us recognize you as a unique user when you return to our website so that you do not have to input your details multiple times as you move between our pages or services.

 Collect and compile anonymous, aggregated information for statistical and evaluation purposes to help us understand how users use the website and help us improve the structure of our website.

Persistent cookies are stored on your device after you close your browser and may continue to exist until they expire or you delete them.

We also use cookies categorized as “first-party” and “third-party” cookies.

First-party cookies belong to us and are set directly by us, from the domain name of the website displayed in the URL window whereas third-party cookies are set by a domain name other than the one being visited by the user. We may use other companies’ web analytics services, such as Google Analytics, which use automated means to help us evaluate how users behave on our website. If you would like to opt out of Google Analytics, Google has developed an opt-out browser add-on that you can download and install for your web browser here: https://tools.google.com/dlpage/gaoptout To learn more about Google Analytics, please visit https://marketingplatform.google.com/about/

The table below sets out the categories of Cookies and purpose for which they are used on our website:

Types of Cookies

Purpose

Required

These cookies are strictly necessary to run our website, to keep it secure, and to comply with applicable laws and regulations. These cookies do not store personal data.

Functional

These cookies enhance the functionality, performance, and service of the website. They remember your region or country, language, accessibility options and your settings. These cookies do not track your activity or store any personal data.

Performance/Analytics

These cookies are used to collect information about how our website is used, including the number of visitors, pages visited, how the user navigated to our website, your computer or mobile device identifier, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on our website.

Social Media

These cookies are used when you share information using a social media sharing button on our websites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The cookies do not directly identify you or store your personal data, however they can uniquely identify your browser and internet device.

Marketing/Advertising

These cookies help us determine which of our products, services may be appropriate for you. From time to time, we may use cookies delivered to us by third parties to show you ads for our products that may interest you. Please see the Behavioral Advertising and Opt Out section below for more information.

Behavioral Advertising and Opt Out

To manage the use of targeting and advertising cookies on this website, go to the tab on the banner at the bottom of our InvestCloud.com website or visit your individual browser settings for cookies. Many browsers allow you to block third-party cookies. You can also clear any existing cookies from within your browser. If you are a California resident, see Section 13. for more information on your choices with respect to cookies.

To learn more about targeted advertising and how to opt-out please visit the non-exhaustive list of organizations or programs below: · Network Advertising Initiative (USA) · Digital Advertising Alliance (USA) · European Interactive Digital Advertising Alliance (Europe) · Digital Advertising Alliance of Canada (Canada)

Please note that all of the external sites referenced through this Privacy Notice are here to help you. However, InvestCloud accepts no responsibility or liability for the content, accuracy or availability of any external site you may encounter.

6. How We Use Your Personal Data

We use your personal data when acting as “data controller” or “business” (as such terms are defined under applicable law) for the following purposes:

 Operating our websites. We are obligated to perform our contract with you for the use of our websites and services and to fulfill our obligations under the applicable terms of use and service; to the extent we do not have a contract in place, we process your personal data based on our legitimate interest to operate and administer our websites and to provide you with information, offer an improved website user experience, and/or protect and maintain our websites.

 Protecting our business and managing the security of our environments is based on our legitimate interest to protect our systems and rights, and the rights of others.

 Managing our commercial relationship with you and your company, such as by sending invoices and making payments. This processing is necessary to perform our contract with you.

 Communicating with you regarding our products and services and general inquiries. If you contact us by email, social media or other method, we process information about you to interact with you and to respond to your requests. It is in our legitimate interests to communicate with you and fulfill your requests.

 Managing our recruiting and processing employment applications. We process personal data, such as information submitted to us in a job application, to recruit and evaluate job candidates for employment based on our legitimate interests.

 Complying with applicable laws and regulations and to operate our business. This type of processing is necessary to comply with our legal obligations.

 Managing event registrations and training. When we plan an event or provide training, we process your personal data to perform our contract with you.

 Administrating office visitors. We may require your registration when visiting our offices for security reasons including the protection of our confidential information against unauthorized access, which represents processing based on our legitimate interests.

 Marketing our products, services, or events. We may use your personal data to form a view of what products or services we think may be of interest to you. Our direct marketing is based on our legitimate interest or, if provided, your prior consent. You can let us know at any time if you no longer wish to receive marketing communications by contacting support@investcloud.com.

 To facilitate communication with our partners, who provide services in combination with our applications.

7. How we Secure Your Personal Data

We have implemented technical, physical, and operational safeguards designed to prevent unauthorized or accidental access, loss, disclosure, or alteration of personal data; to maintain data accuracy; and to ensure appropriate use of personal data. Despite our reasonable efforts to protect personal data, however, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.”

8. How We Share or Disclosure Personal Data

InvestCloud may disclose your personal data to the following categories of third parties:

 Service providers who process information on InvestCloud’s behalf;

 Professional advisors (such as lawyers, auditors and insurers);

 Buyers or other third parties in connection with or anticipation of an asset sale, merger, bankruptcy or other corporate transaction or potential corporate transaction;

 Our corporate affiliates within InvestCloud, to the extent such disclosure is necessary to fulfill your request; or

 Law enforcement agencies, government bodies (including tax authorities) or private parties as required by law.

Disclosures of personal data may be necessary for the performance of our contract, our legitimate interests, or when we are required to do so by law. For any recipient categories not mentioned above, we may transfer your personal data where you have given us permission to do so.

9. Sensitive Personal Information and Children

We ask that you not send us or disclose any sensitive personal data (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or trade union membership) on or through our websites or via other means.

Our websites, products and services are not directed at children nor do we knowingly collect information from anyone under the age of 16.

10. International Transfers of Personal Data

InvestCloud is headquartered in the United States and has office locations and third-party relationships outside of the United States. If we make a transfer of personal data to our InvestCloud affiliates or third-parties as described in section 8. above, we will require that the recipients of your personal data provide data security and protection in accordance with applicable law.

11. For How Long Do We Retain your Personal Data

The personal data you submit to us will only be retained for as long as is necessary for the purposes for which it was collected as outlined in this Privacy Notice, unless a longer retention period is permitted or required by law or our legal obligations. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the services, resolve a dispute, enforce our contractual agreements, or protect ourselves from a claim.

12. Your Rights

You may have certain rights relating to your personal data, subject to applicable local data protection laws.

If you are located in a jurisdiction with data protection laws that provide individuals with certain rights, such as Europe, some or all of the rights described below may be available to you regarding your personal data held by us. If you are a resident of California, please see Section 13. below for information on the rights available to you.

 Access. You may ask us for a copy of the personal data we hold about you, as well as know more about how we process your personal data.

 Correction. If any personal data we hold about you is incomplete or inaccurate, you can request that we rectify it, subject to our verification of the accuracy of the new data you provide to us.

 Erasure. This is a request to delete or remove your personal data and is subject to limitations. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below).

 Object. You may object to processing your personal data for direct marketing purposes or where our processing is based on legitimate interests.

 Restriction. To the extent permitted by law, this right would restrict our processing of your personal data.

 Transfer to another data controller. To the extent possible for personal data provided to perform a contract with you or based on your consent, we will provide to you, or a data controller you have chosen, your personal data in a structured, commonly used, machine-readable format.

 Withdraw consent. Where our processing is based on your consent, you may withdraw that consent at any time.

 Automated Decision-Making currently does not take place on our websites or in our services.

If you would like to exercise rights that may be available to you, please notify us at compliance@investcloud.com. We will respond to all legitimate requests promptly and, in any event, within any timeframes prescribed by applicable law.

If you have not submitted your personal data directly to us, but to one of our clients or customers, please reach out to them directly to exercise any rights that may be available to you. When we act as a data processor we are not responsible for the obligations of the data controller, including the provision of the individual rights stated above.

13. Additional Information for California Residents

This section applies to you only if you are a California resident. For purposes of this section, the terms “personal information,” “sell,” and “share” have the meanings as defined in the California Consumer Privacy Act of 2018 (“CCPA”).

Collection, Use and Disclosure of Personal Information

In the preceding 12 months, we collected the categories of personal information described in Section 4. above (from the categories of sources described in that section). While we do not sell personal information in the traditional sense, we may “sell” or “share” personal information as those terms are defined under the CCPA for the business or commercial purposes described in Section 5. above. We have disclosed the following categories of personal information to the following categories of recipients and for the following business purposes:

Categories of personal
information

Business purposes for which we
may use personal information

Recipients to whom personal
information may be disclosed

Identifiers;

Commercial information;

Internet activity information;

Financial information;

Professional and
employment-related
information;

Education information;

Inferences drawn from any of
the above information
categories.

Providing, personalizing, and
improving our products;

Providing marketing
communications to you, including
ads;

Analyzing and validating your
qualifications;

Communicating with you.

Apps, websites, and third-party
integrations on or using our
applications;

New owners in the event of a
change of ownership or control of
all or part of our products or their
assets changes;

Partners, including partners
offering services in combination
with our applications;

Law enforcement, courts,
governments and regulatory
agencies, in connection with legal
requests, to comply with
applicable law;

Vendors, including measurement
and marketing vendors.

The criteria we use to determine how long to retain your personal information is described in Section 11. above. We do not have actual knowledge that we have ever “sold” or “shared” personal information of children under 16.

As a resident of the State of California, you are entitled to exercise the rights described below free from discrimination:

As a resident of the State of California, you are entitled to exercise the rights described below free from discrimination:

• Access. You may request a copy of the personal information that we maintain about you.

• Deletion. You can ask us to delete the personal information that we maintain about you.

• Know. You can request more information about how we have collected and used your Personal Information during the past 12 months, subject to limitations as stated in the CCPA.

• Correct. You can ask us to correct inaccurate personal information we maintain about you.

• Opt-Out of Sharing. You may opt-out of our use of some cookies involving third-parties by following the instructions in section 5 above. In the event you enable your browser settings to transmit an “opt-out preference” signal we will process that accordingly. You will need to enable such preference on each browser, and on each device that you use.

How to Exercise Your Rights as a California Resident

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

14. How to Contact Us

Should you have any questions about our privacy practices or this Privacy Notice, please email us at compliance@investcloud.com or contact us at 700 N. San Vicente Blvd G605, West Hollywood, CA 90069 or (888) 800-0188.

This version of the privacy notice is effective and current as of the 1st of December 2023 – Version 1.4