Privacy Policy
Last Updated: March 1, 2024
Vestible Assets, LLC (“Vestible”, “we”, “us”, or “our”) respects your privacy. This online privacy notice (“Privacy Notice”) describes the processing of Personal Information (defined below) that is provided, collected, or shared on the website(s), applications, or other platforms that link to this Privacy Notice (collectively, “Services”). It also describes your choices about the collection, sharing, and use of your Personal Information. If we materially modify this Privacy Notice, we will notify you of such change and will conspicuously post an updated Privacy Notice on the Services. Your continued use of our Services after this Privacy Notice has been updated (and after advance notice for a major change) indicates your understanding and acceptance of the updated version of the Privacy Notice
SECTION 1: Personal Information we collect
For the purposes of offering you the Services, we may collect limited Personal Information from you. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. We may collect the following Personal Information:
- Contact Information – If you submit an inquiry or open an account with us, we may collect your contact and mailing information. This may include your name, email address, and phone number.
- Financial Information – If you choose to add an investment entity through the Services we will collect your financial information, including your name, payment information, and information about the entity
- Location Data – data about the location of your device at the time of using the Services. We will collect this information based on the settings of your phone and browser.
- Usage Information – your Internet Protocol Address (IP Address), browser type, domain names, referring URLs, and information on your interaction with the Services.
- Communication Information – any data files you uploaded, e-mailed, or otherwise transmitted to the Services, the contents of your communications with us, and inferences we may make from other Personal Information we collect.
SECTION 2: How we collect your Personal Information
We collect your Personal Information in a variety of ways:
- We may collect your Personal Information directly from you – for example, if you request information from us through the Services, we will ask you to provide us with certain Personal Information.
- We may also collect Personal Information from third parties – for example, we may work with business partners, advertising networks, and analytics providers who may provide us with Personal Information about you.
- Through online tracking technologies – we and our service providers may use cookies device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Services.
SECTION 3: Cookies and Other Tracking Technologies
We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Services, to enhance your experience through personalization, and to help us better understand the features of the Services that you and other users are most interested in.
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Services may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.
Cookies
We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Site, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to market and advertise certain Services to you, to personalize your experience while using the Services, to recognize your computer to assist your use of the Services, and to improve the design and functionality of the Services.
Pixel Tags and Other Similar Technologies
We collect data from pixel tags (also known as web beacons and clear GIFs), which are used to, among other things, track the actions of users of the Services, measure the success of our marketing campaigns, and compile statistics about usage of the Services.
Analytics
We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt out by visiting http://www.adobe.com/privacy/opt-out.html.
SECTION 4: How we use Personal Information
To the extent permitted by applicable law, we may use your Personal Information to:
- operate the Services and provide support to our business functions,
- protect against criminal activity, claims, and other liabilities,
- send you information about our company, Services, and promotions,
- respond to reviews, comments, or other feedback provided to us,
- protect the security and integrity of the Services,
- respond to inquiries and provide customer support,
- to train or facilitate the training of artificial intelligence algorithms, services, or products,
- the extent required for benchmarking, data analysis, audits, enhancing the Services, application development, improving the Services, creating new services, conducting research, analysis, or surveys, identifying usage trends, as well for other analytics purposes,
- meet our contractual requirements,
- comply with applicable legal or regulatory requirements and our policies, and
- the extent necessary for any other lawful purpose for which the Personal Information is collected.
We may aggregate data that we collect, and this aggregated data will not personally identify you or any other user. We may use aggregated data in any way that is permitted by law.
SECTION 5: Sharing of Personal Information
- For legal or safety reasons – when we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of our terms, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Vestible’s intellectual property, the Services, or the public against harm.
- To facilitate transactions involving third parties – certain third-party products may be made available to you through the Services in which we must share your Personal Information with such third parties to facilitate the offer, purchase, sale, and delivery of the products.
- To service providers and suppliers – when we engage a service provider or supplier to help operate the Services, we may give such service provider or supplier access to Personal Information as necessary to perform or provide the Services.
- In the case of a merger or sale – if and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
- To business partners – we may share Personal Information with our trusted business partners.
SECTION 6: How we protect your Personal Information
We use commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.
SECTION 7: Retention and deletion of your Personal Information
We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law. If you are a California resident, please see the Section 12 below.
SECTION 8: Your rights and choices
If you live somewhere other than California, you may have the following rights with respect to your Personal Information:
- Access – you may have the right to know what Personal Information we have collected about you and to access such data.
- Data portability – you may have the right to receive a copy of your Personal Information in a portable and readily usable format.
- Deletion – you may have the right to delete your Personal Information that we obtained, subject to certain exceptions.
- Correction – you may have the right to correct inaccuracies in your Personal Information.
- Opt-out of certain processing – you may have the right to opt out of the processing of your Personal Information for purposes of (a) targeted advertising, (b) the sale of your Personal Information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effect concerning you.
If applicable, to exercise any of these rights available to you, see Section 13 below.
SECTION 9: International Use of the Services
If you are visiting our website from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our data center and servers are located and operated.
SECTION 10: Children
We do not knowingly collect or solicit any Personal Information from children under the age of sixteen (16). In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at or contact us using the information listed in Section 14.
SECTION 11: Links to third-party websites
We are not responsible for the practices employed by any websites or services linked to or from our website, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy notice.
SECTION 12: Notice to California Residents
This Section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.
This Section describes (a) the categories of Personal Information collected and disclosed by us, (b) your privacy rights under the CCPA, and (c) how to exercise your rights. For the information related to our retention of your Personal Information, please see Section 7.
Vestible makes the following disclosures regarding the Personal Information it has collected within the 12-month period preceding the Effective Date of this Privacy Notice
Sources of Personal Information
We collect Personal Information from the categories of sources detailed in Section 2 above: (a) directly from you; (b) from third parties, and (c) through data collected automatically through tracking technologies.
Use of Personal Information
We collect Personal Information for the business and commercial purposes detailed in Section 4 above.
Disclosure of Personal Information
The categories of third parties to which we disclose Personal Information for a business or commercial purpose or to whom we sell or share personal information are summarized in the chart below.
| Categories of Personal Information we collect from California consumers | Categories of third parties we disclose Personal Information for our business purpose | Categories of third parties in which we may share or sell Personal Information |
|---|---|---|
| Internet or other similar network activity | Service Providers or Third-Party Sellers | Third-Party Analytics Providers, Advertising or Marketing Partners, or Third-Party Sellers |
| Geolocation data | Service Providers | Third-Party Analytics Providers, Advertising or Marketing Partners, or Third-Party Sellers |
| Inferences drawn from other Personal Information | Service Providers or Third-Party Sellers | Third-Party Analytics Providers, Advertising or Marketing Partners, or Third-Party Sellers |
Subject to certain exceptions, if you are a resident of California, you may have the following rights:
| Privacy Right | Description |
|---|---|
| Notice | You may have the right have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared. |
| Access | You may have the right to know what Personal Information we have collected about you, including (a) the categories of Personal Information; (b) the categories of sources from which the Personal Information was collected; (c) the business or commercial purpose for collecting, selling, or sharing Personal Information; (d) the categories of third parties to whom the business discloses Personal Information; and (e) the specific pieces of Personal Information we have collected about you. |
| Data Portability | You may have the right to receive a copy of your information in a portable and readily usable format. |
| Delete | You may have the right to have your Personal Information deleted. Note, however, that we may not always be able to comply with your request to delete for specific legal reasons which will be notified to you, if applicable, at the time of your request. |
| Correction | You may have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. |
| To Opt Out of Sales or Sharing of Personal Information | You have the right to opt out of the sale and sharing of your Personal Information. In order to fully exercise your right to opt out of the sale or sharing of your Personal Information, please click on the “Do Not Sell or Share My Personal Information” link at the bottom of the Services. |
Only you or your authorized agent may make a request related to your Personal Information. You may only make a request for access or data portability twice within a 12-month period. The request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Other California Privacy Rights
Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of personal information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information in the Contact Us section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
SECTION 13: Exercising your individual privacy rights
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny the Services to you, provide different prices or rates for Services to you, or provide a different level or quality of the Services to you. To exercise any of the privacy rights afforded to you under applicable data protection law, please submit a request by using the contact information in Section 14 below.
Verification
We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.
We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via email, unless you notify us of another preference.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.
We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes.
Appeals
If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.
SECTION 14: Contact Us
If you have any questions about our practices or this Privacy Notice, please contact us at: