ETF INSIDER PRIVACY POLICY

Last Updated: April 15 2023

In order to ensure transparency and give you more control over your Personal Information, this privacy policy (“Privacy Policy”) governs how we, ETF Insider. (together, “ETF Insider” “we”, “our” or “us”) use, collect, disclose, and store Personal Data we collect or receive from or about you (“you”) such as in the following use cases:

  1. When you browse or visit our website, https://etfinsider.co (“Website”)
  2. When you make use of, or interact with, our Website
  3. When you create an account and login to our services

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals, individuals and the "Do Not Sell My Personal Information" mechanism(s) below are only relevant for CCPA-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. How we protect and retain your Personal Data
  3. Your privacy rights
  4. Use by children
  5. Analytic tools
  6. Specific provisions applicable under California privacy law
  7. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

    1. When you browse or visit our Website
    2. When you visit our Website, we collect information about you through cookies, analytic tools and log files. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you register with the Website, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as addresses, username and so on. When you return to the Website, the information you previously provided can be retrieved, so you can easily use the features that you customized. For more information, please read our cookies policy https://etfinsider.co/cookies/. We also use Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Where we do not process this data, certain features of the website would not be available. Our legal basis for collecting this information is consent and/or our legitimate interest (e.g. using essential cookies).

    3. When you make use of, or interact with, our Website
    4. When you request or book a demo, you will provide us with the following information: Full name, email address, phone number, company name and country. We use this information to contact and coordinate with you in order to provide you with the demo. Our legal basis for collecting this information is that processing is necessary in order to take steps at the request of the data subject prior to entering into a contract and/or our legitimate interest (e.g. to provide a demo). If we do not process this data, we would not be able to coordinate a time with or provide you with a demo. We also use your name and email details which you provide us with in order to send you marketing communications. Our legal basis for doing so is the consent you give us for the purpose of marketing communications and/or our legitimate interest. Where we do not process this information in this manner, we would not be able to send you marketing communications.

    5. When you create an account and login to our services
    6. You will provide us with the following information: Full name, email address,. We collect this information in order to allow you to create an administrator user and access our services. We also use this information in order to allow us to perform/execute the agreement, to manage your everyday business needs (i.e., website administration), to answer your requests for services and for related activates (e.g., account management support and to provide other related services), to producing general statistics and statistical information regarding use of our software in general. Our legal basis for collecting this information are that processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and legitimate interest (e.g. to sign up).

  2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

    1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

    2. Retention of your Personal Data. In some circumstances we may store your Personal Data for longer periods of time after the end of the engagement, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy.

  3. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

    1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

      1. You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
      2. You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
      3. You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
      4. You have the right to object, to or to request restriction, of the processing;
      5. You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
      6. You have the right to object to profiling;
      7. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
      8. You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
      9. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
    2. The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by the CCPA:

      1. You have the right to know what Personal Information is being collected about you. This include the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;
      2. You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
      3. You have the right to know whether your Personal Information is sold or disclosed and to whom;
      4. You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA;
      5. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.
    3. You can exercise your rights by contacting us at privacy@etfinsider.co. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

    4. Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@etfinsider.co. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

  4. USE BY CHILDREN

    We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@etfinsider.co.

  5. ANALYTIC TOOLS

    Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/ and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

    We reserve the right to remove or add new analytic tools.

  6. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

    1. This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.
    2. Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permit you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
    3. Sale of Personal Information. Disclosure of Personal Information for business purposes. Financial incentives for collection of Personal Information: We do not sell any Personal Information and we do not disclose any Personal Information for any business purpose. Therefore, we have not sold or disclosed consumers’ Personal Information for a business purpose in the preceding 12 months. Also, we do not offer financial incentives for collection of Personal Information. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@etfinsider.co. Please note that the email must come from the email account you wish to block.

    4. Non-Discrimination. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our website, our products and/or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:

      1. Deny you goods or services.
      2. Provide you a different level or quality of goods or services.
    5. Deletion Of Content From California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to at privacy@etfinsider.co. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

  7. CONTACT US

    If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@etfinsider.co.