As a registered investment adviser, Exchange Traded Concepts, LLC (“Exchange Traded Concepts” or “ETC”) must comply with U.S. Securities and Exchange Commission Regulation S-P (and any other applicable regulations), which requires registered investment advisers (i) to adopt policies and procedures to protect the “nonpublic personal information” of natural person consumers and customers (referred to herein collectively as “clients”) and (ii) to disclose to clients their policies and procedures for protecting that information. Nonpublic personal information includes nonpublic “personally identifiable financial information” plus any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Exchange Traded Concepts to clients, and data or analyses derived from such nonpublic personal information (collectively, “client information”). Except as set forth below, Exchange Traded Concepts may not share any of the client information that it collects.
Exchange Traded Concepts’ Chief Compliance Officer (the “CCO”) is responsible for reviewing, maintaining and enforcing this policy and related procedures to ensure meeting Exchange Traded Concepts’ client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations. The CCO may recommend to Exchange Traded Concepts’ senior management any disciplinary or other action as appropriate. The CCO is also responsible for distributing this policy and related procedures to Supervised Persons and conducting appropriate training to ensure Supervised Person adherence to this policy and related procedures. Since the only clients of Exchange Traded Concepts are multiple series trusts and a private fund that ETC subadvises. Exchange Traded Concepts does not possess nonpublic personal consumer information and is not obligated to distribute a privacy notice or statement Each series trust maintains and distributes its own privacy notice as applicable.
This policy includes various procedures adopted by Exchange Traded Concepts to implement this policy and to monitor and ensure that this policy is observed, implemented properly and amended or updated, as appropriate, including the following:
Disclosure of Client Information
Exchange Traded Concepts maintains safeguards that comply with federal and state standards to protect the security of client information. Exchange Traded Concepts does not share any client information with any affiliate or nonaffiliated third parties, except as permitted by law, such as in the following circumstances:
Supervised Persons are prohibited, either during or after termination of their employment, from disclosing client information to any person or entity outside Exchange Traded Concepts, including family members, except under the circumstances described above. A Supervised Person is permitted to disclose client information only to such other Supervised Persons who need to have access to such information to deliver our services to the client.
Security of Client Information
Exchange Traded Concepts restricts access to client information to those Supervised Persons who need to know such information to provide services to Exchange Traded Concepts’ clients. Any Supervised Person who is authorized to have access to client information is required to keep such information in a secure compartment or receptacle on a daily basis as of the close of business each day. All electronic or computer files containing client information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving client information, if appropriate at all, must be conducted by Supervised Persons in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.
EXCHANGE TRADED CONCEPTS
Last updated: June 1, 2021
Exchange Traded Concepts, LLC (“Exchange Traded Concepts”, “ETC”, “us”, “we”, or “our”) is committed to protecting the privacy of all individuals who utilize our website or any of our services. Please read the following statement to understand how we collect, use and safeguard the information you may provide to us via your use of this website (the “Site”).
If you do not agree to the terms of this Privacy Statement, please do not provide us with any information and do not use the Site. By using the Site and voluntarily providing your personally identifiable information to us, or by voluntarily providing your personally identifiable information to us through any other means, you consent to the collection and use of such personally identifiable information as set forth in this Privacy Statement.
This Privacy Statement is effective as of the date listed above. We may revise this Privacy Statement at any time so please check from time to time for such revisions. Any changes to this Privacy Statement will be effective as of the date they are posted. If you have specific questions regarding this statement or any information you have submitted via the Site, please do not hesitate to contact us at Info@ExchangeTradedConcepts.com.
COLLECTION AND USE OF YOUR INFORMATION (INCLUDING VIA COOKIES)
Via the Site, Exchange Traded Concepts collects from you: (i) personally identifiable information, (ii) technical information about your device and browser and (iii) other information. Exchange Traded Concepts is the data controller of the information you provide us.
- Personally Identifiable Information
Information Requests and/or Subscriptions – At the time you request additional information or subscribe to a newsletter through the Site, we request that you provide us your name, organization, email address, investor type and phone number.
Contacting Us – The Site permits you to contact us via email. Whenever you send an email via an email link on the Site, you will be providing us with your name and email address and any information you choose to include in the text of your message. For example, you may choose to provide your mailing address, phone number or other information necessary or helpful for us to address your query or other concern.
Processing of data is in furtherance of legitimate business interests, while seeking to ensure your legal rights aren’t infringed. We use this information for the purpose of conducting business with you or your firm, managing our relationship with you or your firm, and advising you or your firm of products and services that we believe might be of interest.
If you are an individual in the European Economic Area (EAA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. We collect and use your information only where:
- Technical and Other Anonymous Information
A Cookie is a small piece of information that a website stores on the web browser on your device and can later retrieve. “Session” Cookies are temporary and will expire at the end of a browser session; that is, when you leave a website. Session Cookies allow a website to recognize you and carry information as you navigate between pages during a single browser session and allow you to use the website more efficiently. “Persistent” Cookies remain in the Cookie file of your browser even after you leave a website and after the browser is closed. They enable a website to recognize you on your return, remember your preferences and provide tailored services to you. A Cookie will not contain information that will enable us to contact you via telephone, e-mail, or other means.
Cookies on the Site are used to:
- Remember your preferences,
- Enable us to provide the services you requested on the Site
- Measure your use of the Site so that we can improve it, enhancing your overall experience, and
- Diagnose problems with the Site.
Most browsers are initially set to accept Cookies. However, you have the ability to change your internet browser settings. It may also be possible to configure your browser settings to enable acceptance of specific Cookies or to notify you each time a new Cookie is about to be stored on your device enabling you to decide whether to accept or reject the Cookie. You can also disable Cookies by configuring your browser setting to reject Cookies. Please refer to the help section of your browser for instructions on disabling Cookies. For more information about Cookies, how they work, why they are so useful and how to disable them, please visit www.allaboutcookies.org.
If you do not wish to accept Cookies from this Site please either disable them or refrain from using this Site. You should be aware that that disabling Cookies may affect the appearance of the Site on your device and limit your browsing experience (including reduced functionality) and you may be prevented from using some, or all of, the Site.
In addition to the above uses, we may use your information for the purpose of conducting business with you; managing our relationship with you; to respond to an inquiry from you or address a request submitted by you (including contacting you directly to request additional information to process your inquiry or request); to contact and provide you information regarding Exchange Traded Concepts and/or our business partners; to correspond with you regarding the Site, products or services; to inform you of developments in our company or with our services that we believe may be of interest; to comply with applicable laws and requests of relevant regulatory and law enforcement and/or other governmental agencies; and/or to protect the rights, property, or safety of Exchange Traded Concepts, our users, and others.
SHARING OF YOUR INFORMATION
We do not sell or rent your personally identifiable information to third parties. We share your information only with our (i) service providers that have agreed to confidentiality restrictions and use any personal information they collect on our behalf solely for the purpose of providing the contracted service to us; (ii) to the extent reasonably necessary to prevent fraud and unauthorized transactions (iii) as otherwise described herein in order to provide you with our services; and (iv) to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies. Also, we may share in aggregate, statistical form, non-personal information regarding the visitors to the Site, traffic patterns, and Site usage with our partners or advertisers.
We may also export your information to other jurisdictions outside of the United States where we, our partners or our service providers do business.
Exchange Traded Concepts may, in the future, sell or otherwise transfer some or all of its assets to a third party. Your personally identifiable information, technical information about your device or browser and/or other anonymous information we obtain from you via the Site may be disclosed to any potential or actual third-party purchasers of such assets and/or may be among those assets transferred.
THIRD PARTY ADVERTISERS
MODIFICATIONS TO YOUR DATA
If you wish to review and/or make any changes to any personally identifiable information we have collected from you through your use of the Site, or that you have provided to us, you may do so at any time by contacting us at Info@ExchangeTradedConcepts.com.
In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501-06 and 16 C.F.R. §§ 312.1-312.12, the Site does not permit children under 13 years of age to become users, and we do not collect information from children. By using the Site, you represent that you are not under 13 years of age.
THIRD PARTY WEBSITES
SECURITY OF PERSONAL INFORMATION
Exchange Traded Concepts has appropriate technical and organizational measures in place, as required by law, to maintain the security of any personal information it collects. We take reasonable steps to protect your personally identifiable information as you transmit your information from your computer to our site and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them.
NOTICE TO CALIFORNIA USERS REQUIRED BY STATE LAW
We collect, use, retain and share with third-parties information we receive through this Site or other means in accordance with the above sections entitled Information Exchange Traded Concepts Collects From You, Collection And Use Of Your Information (Including via Cookies) and Sharing of Your Information. The Site currently does not respond to “do not track” signals or similar mechanisms. Please see the above section entitled Modification to your Data for directions on how to access and change any personal information that we have collected or that you have provided us. For information about whether third parties may collect personal information about you, or your online activities over time and across different websites see the above section entitled Third Party Websites.
What are your data protection rights?
Exchange Traded Concepts would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request Exchange Traded Concepts for copies of your personal data.
The right to rectification – You have the right to request that Exchange Traded Concepts correct any information you believe is inaccurate. You also have the right to request Exchange Traded Concepts to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Exchange Traded Concepts erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Exchange Traded Concepts restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Exchange Traded Concept’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Exchange Traded Concepts transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: Info@ExchangeTradedConcepts.com
Call us at: 1-844-880-ETFS (3837)
Or write to us: 10900 Hefner Pointe Drive, Suite 400, Oklahoma City, OK 73120
If you have specific questions regarding this Privacy Statement or any information you have sent via the Site, please do not hesitate to contact us at Info@ExchangeTradedConcepts.com.
This Privacy Statement was last updated on the date listed at the top.