VectorVest Privacy Policy

VectorVest Privacy Policy

VectorVest respects your privacy and is committed to protecting your privacy. VectorVest provides factual information, research and education services in respect of securities, derivatives and managed investments.

This policy sets out our approach to the management of personal information. It is important to read this policy, together with any other privacy policy or fair processing policy we may provide on specific occasions, so that you are aware of why we are using this data. We keep our policy under regular review. We may amend this Policy from time to time, should it become necessary or advisable to do so to comply with regulatory requirements or best practices. This version was last updated on May 3, 2024.

About us

VectorVest is a trading name for VectorVest Inc., a company incorporated in the United States with its headquarters at 2650 W. Market Street, Akron Ohio 44333 and its affiliate European Financial Publishing Ltd, a company incorporated in Scotland with the company number SC357322 and registered office at Exchange Tower, 19 Canning Street, Edinburgh, Midlothian, EH3 8EH (together “VectorVest”, “we”, “us”, “our”).

Depending on the entity you engage with or where you are based, the data controller (and/or where relevant the data processor) for the purposes of data protection laws shall be as follows:

Jurisdiction

Entity

Contact Details

US and Canada

VectorVest Inc.

2650 W. Market Street

Akron OH 44333

1-888-658-7638

support@vectorvest.com

UK and elsewhere

European Financial Publishing Ltd.

2650 W. Market Street

Akron OH 44333

1-888-658-7638

support@vectorvest.com

Purpose of this policy

To provide you with information, systems, and other services, we may collect and retain personal information that may identify you or contribute to identifying you.

“Personal information” can include information such as your name, email address, your photo, contact details and, in some cases, general financial information. We will not collect your personal information unless it's necessary to provide the information, advice or service you've requested (or for other purposes as set out in this policy) and, where possible, you’ll be able to use our services anonymously.

We will only collect your personal information from you or from someone you’ve authorised to provide it to us. We will also only collect information by lawful and fair means and not in an unreasonably intrusive way.

Because we take your privacy seriously, we will take reasonable steps to ensure that you are aware of:

who we are and how you can contact us; and
how you can gain access to the information we have collected about you; and
the purposes for which the personal information is collected; and
the organizations (or the types of organizations) to which we may disclose your personal information; and
the laws that require us to collect this information; and
the main consequences (if any) for you if you choose not to provide us with personal information about you.

For processing carried out by VectorVest when acting as a data controller in Australia or in respect of any processing of personal information relating to data subjects in Australia, please see Annex 1 (in addition to the other provisions set out in this policy) which meets applicable data protection legislation. Where there is a conflict between Annex 1 and the rest of the privacy policy, Annex 1 shall prevail.

For processing carried out by VectorVest when acting as a data controller in the European Economic Area (“EEA”), UK or Switzerland, or in respect of any processing of personal information relating to data subjects in the EEA, the UK or Switzerland carried out by VectorVest when acting as a data controller, please see Annex 2 (in addition to the other provisions set out in this policy) which meets applicable data protection legislation. Where there is a conflict between Annex 2 and the rest of the privacy policy, Annex 2 shall prevail.

VectorVest complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. VectorVest has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. VectorVest has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

When we collect your information

We may collect personal information about you in the following instances:

you use our website including filling out any forms, surveys or contacting us;
you interact with us on social media or otherwise;
we provide services to you or you access our services;
from third parties such as analytical providers; or
you otherwise provide personal information to us.

This privacy policy further applies to personal information and data collected of any kind or nature whatsoever provided by you or in connection with or in relation to www.vectorvest.com, www.vectorvest.ca, www.vectorvest.be, www.vectorvest.de, www.vectorvest.com.au, www.vectorvest.co.uk, www.vectorvest.nl and also to personal information and data of any kind or nature whatsoever provided by you or collected by VectorVest, or others for or in connection with or in relation to any of its courses, training, software, applications, licenses, research, subscription services, free trials, marketing, and any and all other products and services it offers on its own or may offer on behalf of or through or integrated with third parties (all such products, services and activities collectively the “Services”) in relation to all formats and mediums including at additional websites or applications that may not be listed here. This privacy policy also applies to all personal information and data you provide to VectorVest of any kind or nature, for any reason.

How we use personal information

We collect personal information from you to provide you with services, advice and information including:

confirming your identity;
communicating with you;
administering our services;
notifying you of the services we offer;
carrying out marketing, training or promotional activities;
responding to feedback, comments, or any other contact;
sending you email(s) or newsletters to which you have subscribed;
helping you to resolve technical issues with our site;
in marketing, educational and promotional material (and then only with your express permission).

We will only use your personal data when the law allows us to. Generally, by using our services, you consent to us collecting, holding and using your personal information in this way. However, we may also rely on other legal basis to process your personal data for users / customers based in the EEA, UK or Switzerland (see Annex 2).

We may also access, hold and use aggregated information about the people that use our services. Aggregated information won’t identify you or any other individual but simply provides us with non-personally identifiable data that we’ll use to improve our services, understand our users’ needs and develop tailored content. Although you would have provided us with the information we aggregate for these purposes, it won’t identify you or enable you to be personally identified.

Information VectorVest collects

We only collect the information you provide to us so, to a great extent, when you use our services, you can determine how you are identified.

Users can visit the public or “free” sections of our websites without identifying themselves or volunteering personal information. But to otherwise utilize the Services and associated features, a user must first register with VectorVest. When a user registers, we may request certain personal information, including, but not limited to, contact information, such as the users name, mailing address, telephone number, e-mail address, credit/debit card information, transactional payment information, and demographic information such as age and gender. VectorVest collects personal information when a user voluntarily provides VectorVest with this information or where such information is required or permitted to be collected by law or professional standards.

Please use your discretion when providing sensitive information to VectorVest, and under any circumstances. This site is being monitored by one or more third-party monitoring software(s) and may capture information about your visit that will help us improve the quality of our service. You may control the data being collected from your visit by visiting https://sitespyiq.com through a universal consumer options page located at: https://sitespyiq.com/Unsub/unsub.html.

BY REGISTERING AND/OR SUBMITTING PERSONAL INFORMATION TO VECTORVEST, YOU CONSENT TO VECTORVEST’S USE OF THIS INFORMATION FOR BUSINESS PURPOSES AND AS DESCRIBED HEREIN AND CONSENT TO THE TRANSFER AND STORAGE OF SUCH INFORMATION TO AND IN VECTORVEST’S DATABASES IN ACCORDANCE WITH THIS PRIVACY STATEMENT. BY REGISTERING AND/OR SUBMITTING PERSONAL INFORMATION TO VECTORVEST, YOU CONSENT TO VECTORVEST’S PROVIDING AND DISSEMINATING THIS INFORMATION TO THIRD PARTIES FOR BUSINESS PURPOSES AND CONSENT TO THE TRANSFER AND STORAGE OF SUCH INFORMATION TO AND BY SUCH THIRD PARTIES (FOR EEA, UK, OR SWITZERLAND RESIDENTS PLEASE SEE ANNEX 2, WHICH ARE INCORPORATED HEREIN BY REFERENCE SPECIFIC TO SUCH JURISDICTIONS ONLY AS IF SET FORTH IN FULL). Your personal information is not used by us or provided to third parties for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards.

Purposes of Data Collection

VectorVest gathers, collects, stores, organizes, and retrieves information and data about users of the Services both collectively and individually.

For example, we gather what areas of our websites users visit most frequently, what Services users access most often, and trends or patterns in response to educational course questions.

All data collected by VectorVest will be stored in SalesForce.com and other business systems, as appropriate for the purpose of providing Services to you. All hosting is performed in accordance with security regulations. VectorVest automatically logs IP addresses, session sources, and other data which tracks users’ access to the Services. We analyze these logs for sales and marketing purposes, as well as for system performance monitoring. These logs are analyzed for the aggregate trends and patterns they reveal about users of the Services, not for the behaviors of individual users. This information provides us with aggregate data that VectorVest may use to improve the Services.

VectorVest also gathers personal information about users of the Services individually, for example for provision of customer service and support, billing, security, compliance with the VectorVest Subscriber Agreement, network management, user surveys, sales management, sales support, newsletters, marketing, user group memberships, event registrations, sponsorships, offers of related products and services, and other exchanges of information.

We may also use the information you send to us to communicate with you via email, and possibly other means, regarding products, services, offers, promotions, or events we think may be of interest to you or to send you our newsletter, if this is in accordance with your marketing preferences.

In addition to the foregoing, VectorVest may use aggregated personal information to determine the demographic composition of our user base and to distribute statistics and general marketplace information about VectorVest. This aggregate information does not identify specific users. Certain non-personal information regarding users is recorded by the standard operation of the Internet servers hosting the Services. This information is primarily used to provide users of the Services with an enhanced online experience. VectorVest may disclose aggregated user statistics in order to describe the Services to prospective partners, advertisers, purchasers, and other third parties, and for other lawful purposes.

Some features of the Services may be offered in conjunction with an unaffiliated third party, such as another entity, service provider or brokerage offering or integrating with the Services and contracting with VectorVest as a vendor or with VectorVest as a client to provide the Services or integration to users. In order to provide the Services or the integration, it may be and sometimes is necessary for users and/or VectorVest to share personal information and data of users with unaffiliated third parties.

Where we rely on your consent, you will always be able to opt-out of such communications at any time through the processes outlined in section 10 below.

For EEA, UK or Switzerland residents, please see Annex 2 for further details.

The Services, including ProfitLocker Pro ™, RoboTrader ™, and Trade Now ™ -- relation to Third Party Yodlee

VectorVest has a contract with Yodlee. As a client of Yodlee, VectorVest uses and integrates with Yodlee to link VectorVest user brokerage accounts with third party brokerages to VectorVest’s Services including, but not limited to, in connection with a VectorVest software product named ProfitLocker Pro™ that is for stop guidance, and to help investors analyze the holdings in their brokerage accounts, to know what to buy, when to buy and when to sell. The Yodlee software may be or is silently integrated into VectorVest’s existing platforms and Services, such that it may appear to the user or consumer of the Services, including of ProfitLocker Pro™, RoboTrader ™, and Trade Now ™ that he or she is interacting with VectorVest and has no idea he or she is logging into or using a Yodlee product. You understand that when you enter your brokerage account credentials and login information (i.e., username and password), account access information and/or registration information, in connection with the Services, including ProfitLocker Pro™, RoboTrader ™, and Trade Now ™, Yodlee has access to it and stores a copy of such information and data on its own system after the connection is made between your brokerage account and any VectorVest product or service.

You understand that once Yodlee has access to your brokerage account and login information, Yodlee may and does routinely extract data from your account. Although we hope it never happens, you understand and agree that there is always a risk that Yodlee or any third party to whom we or you disclose your information and data, might continue to use a stored copy it has made of your information and data or might otherwise violate laws related to your information and data and the use and storage thereof even after you have severed the connection between your brokerage account and the VectorVest product or service or even after you no longer provide consent to the Yodlee or third-party use of the same. Such might be the case despite any representations and assurance made by Yodlee or third parties to VectorVest that such events and use after severance will not occur. For EEA, UK and Swiss residents, please see Annex 2 for further information on the protection measures we adopt to protect your personal informaiton.

You understand and are provided notice that Yodlee has in the past been accused of aggregating individual consumer data and information, including bank account balances and transaction histories, and selling it to third parties for a fee, and that you have been given notice of Yodlee’s alleged business practices and conduct as alleged in a court Complaint concerning consumer data and information and account log-in credentials and the storage and use thereof, which have been appropriately disclosed to you. You agree that you have been informed of the risk of Yodlee or any third party in possession of your information and data continuously accessing and extracting information from your account and selling it to third parties without your knowledge or consent, and that Yodlee’s or any third party’s involvement with your data and information might unfortunately go well beyond the limited consent provided by you to facilitate a connection between your brokerage account and VectorVest, and you willingly and knowingly assume and accept and agree to that risk. In the spirit of providing full disclosure and the facts to allow you to provide an informed consent before using and subscribing the Services, including, ProfitLocker Pro™, RoboTrader ™, and Trade Now ™, VectorVest wishes to advise its users and consumers of the Services and ProfitLocker Pro™. RoboTrader ™, and Trade Now ™ and hereby informs them that Yodlee is currently or once was a defendant party in a class action lawsuit, Case No. No. 3:20-cv-05991 filed in federal court in Northern California in August, 2020, in which the plaintiff, Deborah Wesch, alleges in the Complaint that Yodlee’s business practice of collecting, extracting, and selling personal data violates several privacy laws, such as the California Consumer Privacy Act (CCPA), California’s Financial Information Privacy Act (CalFIPA), the California Online Privacy Protection Act (CalOPPA), and the Gramm-Leach Bliley Act (GLBA) Privacy Rule. The plaintiff has alleged that once Yodlee has access to the individual’s account, Yodlee routinely extracts data from the user’s account, even after an individual has severed the connection between its bank account and the third-party service. The plaintiff has alleged that after access is revoked, Yodlee accesses the account by relying on their own stored copy of the individual’s credentials. The plaintiff has alleged that Yodlee then aggregates the data, including bank account balances and transaction histories, and sells it to third parties for a fee. The Plaintiff alleges that Yodlee continuously accessed and extracted information from her account and sold her personal data to third parties without her knowledge or consent. A copy of the class action Complaint is here.

Additional Information About Disclosures to and interactions with third parties

As a general principle moreover, we will not disclose your personal information without your express permission unless:

we are required to do so by the law, to comply with our obligations or exercise our rights;
it is necessary to lessen or prevent a serious and imminent threat to a person’s health, life or safety;
it is necessary to lessen or prevent a threat to public health or public safety.

IF A USER DOES NOT WANT HIS OR HER INFORMATION TO BE SHARED, THE USER CAN CHOOSE NOT TO ALLOW THE TRANSFER BY NOT USING THE SERVICES, OR BY FOLLOWING THE OPT-OUT PROCEDURES IDENTIFIED IN SECTION 10 BELOW. FOR EEA, UK OR SWITZERLAND RESIDENTS, PLEASE SEE ANNEX 2 FOR FURTHER DETAILS.

Also, please be aware that advertisers or websites or third parties that are linked to or integrated with the Services may and do collect personally identifiable information and data about users. The separate information and data use practices of those websites or third parties linked to or integrated with the Services, including for example Yodlee, are not covered by this privacy policy. To the extent permitted by law, VectorVest is not liable or responsible for the business practices, privacy practices, conduct or the content of such websites or third parties including Yodlee, or for any violations of any laws whatsoever by such websites or third parties, including Yodlee, and VectorVest will provide no indemnity to any party for the conduct of any third parties in connection with your information or data. This lack of liability, responsibility and/or indemnity on the part of VectorVest shall be the case even if VectorVest might be negligent in part in contracting with or using any third party including Yodlee or in disclosing or sharing information or data with any third party.

VectorVest utilizes other companies to provide limited services on its behalf, including but not limited to customer support, web analytics, data aggregation, integrations, coordination of mailings and event management. These companies are permitted by us, in our contracts with them, to access only the information they require to perform those services. VectorVest requires these companies to maintain the confidentiality of any personal information and data and prohibits them from using the information for any other purpose than the purpose for which it was collected or that is unlawful. For example:

We use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the 'about Hotjar' section of Hotiar's support site, https://www.hotjar.com/about-us/.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit https://privacy.microsoft.com/en-us/privacystatement.

We have engaged Inspectlet to analyze the activities of visitors to this website, and Inspectlet's authorized use of cookies and other tracking technologies enable it to have access to Personal Information of visitors to this website. Such access to and use of Personal Information by Inspectlet is governed by Inspectlet’s Privacy Policy, found here, https://www.inspectlet.com/terms-of-service#privacy.

You always assume the full and total risk however that all third parties with whom we share your information and data may not abide by the contractual terms and may violate laws with respect to your information and data and the use, sharing and storing thereof, and VectorVest does not represent or warrant that such third parties are reliable or lawful in their business practices or concerning privacy.

The personal information data users (excluding EEA, UK and Swiss residents) of the Services supply to VectorVest may also be given, sold, rented, loaned, disseminated, or disclosed to third parties outside of VectorVest for sales and marketing purposes and solicitations. If a user does not want his or her information to be shared, the user can choose not to allow the transfer by not using the Services, or by following the opt-out procedures identified in section 10 below.

A user also can view their information, have errors corrected, or have their information transferred.

The personal information and data users of the Services supply to VectorVest may also be given, transferred, disseminated, or disclosed to third parties under special circumstances, such as when we believe in good faith that disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce any terms of use of the Services, (iii) respond to claims that any content provided by using the Services violates the rights of third parties, (iv) protect the rights, property, or personal safety of VectorVest, its users, or the public, (v) enter into or comply with a contract, or (vi) complete an audit of any kind. Please know that VectorVest may be required to release an individual’s personal information in response to a lawful request by public authorities especially to accommodate national security or law enforcement requirements.

VectorVest uses technical, organizational, and administrative security measures to protect information we hold in our records from loss, misuse, and unauthorized access. Unfortunately, no company can guarantee full security. User accounts are protected by a password for privacy and security. Users must prevent unauthorized access to their account by selecting and protecting their password and limiting access to their computer or device and browser.

Personal Information a user submits to VectorVest may be sent, stored, and processed in the United States, Europe, or any other country in which VectorVest or its subsidiaries, affiliates, or service providers maintain facilities. VectorVest may transfer information collected about users, including personal information, to affiliated entities or other parties across national borders. If you are located in the European Union or United Kingdom, or other regions with laws governing data collection and use differing substantially from U.S. law, please note that we will not transfer information without the same or substantially similar data protections in place (see Annex 1 and 2 for further information). These countries may not have similar data protection laws to those in your country of residence. However, VectorVest will protect your information in accordance with this Privacy Policy wherever it is processed.

What is a cookie?

A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information that allows a website to track the pages you’ve visited. But the only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites. VectorVest uses cookies to tell when a user is a repeat visitor and to let us know how the user found the site. They also allow us to automatically link users to their personalized accounts. When you create an account, VectorVest may use a cookie to store a unique, random code. VectorVest only uses this code to identify you anonymously in our database and to track the pages you visit on our site. This helps us better understand and improve areas of the site that our users find valuable. VectorVest also uses this code to enable you to enter various Services areas without having to log in each time.

User Options — Opt-Out

Users of the Services should contact us at the address below with any questions about the information that we collect from users. Where we rely on consent to obtain personal information, users may opt out of receiving any future direct marketing or promotional electronic mailings from VectorVest by following the unsubscribe procedures indicated in the mailing. Additionally, if a user does not want his or her information to be shared, or does not wish to receive telephone solicitations, users may opt out of the sharing or solicitations by calling us at (888) 658-7638, writing to us at the address below, or emailing us at support@vectorvest.com, indicating that he or she wishes to opt out. Users will still receive non-promotional communications such as service-related emails.

User Access to Information

VectorVest acknowledges the individual’s right to access their personal data. If we do hold personal information about you, you can request access to the information we hold. We will not restrict your access to the information unless:

providing access would pose a serious and imminent threat to someone’s life or health;
providing access would pose a serious threat to someone’s life or health; or
providing access would have an unreasonable impact upon someone else’s privacy; or
the request for access is frivolous or vexatious; or
the information relates to existing or anticipated legal proceedings between you and us;
providing access would prejudice our negotiations; or
providing access would be unlawful; or
denying access is required or authorised by or under law.; or
providing access would be prejudicial or commercially sensitive.

If we cannot provide you with access to the information because of one or more of these reasons (which we will confirm in writing) we will consider reasonable alternatives that may satisfy all parties. You will generally be able to access your personal information without cost but, if we think a charge is reasonable it will not be excessive and will not apply to lodging a request for access.

Additional rights are available to those residing in EEA, UK or Switzerland. Please see Annex 2 for further details on your rights.

How do we retain and secure your personal information?

We will only ask for the information we need to provide you with services, advice and information you request from us. When we retain your information, it will only be information you provide and will only be collected and used with your express permission (or some other legal basis for EEA, UK or Swiss residents as set out in Annex 2). We will, and do, take reasonable steps to protect the personal information we hold and prevent the misuse, loss or unauthorised use of the information we hold. We will also take reasonable steps to destroy or permanently de-identify personal information that we do not need or no longer need to retain. Although we maintain a regular plan of recovery in the event of the loss of data stored in relation to products and for the purposes of compliance with internal dispute resolution procedures, we do not routinely store individual personal data except with your express permission (or other legal basis for UK and EU residents). If you engage with us via social media, in a forum or by email you may be providing us with some of your personal information such as names, addresses, phone numbers or email addresses. This information, which may identify you, is generally not retained by us for our broader use.

VectorVest retains personal information from users for as long as the user’s account is active, or otherwise for a limited period of time after that needed to fulfill the purposes for which the information was initially collected or as otherwise required by law. VectorVest will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Billing information will be retained for a period of seven years after any account closure or for a period as otherwise required based on tax and accounting laws. Information regarding legal transactions between VectorVest and a user will be retained for a period of seven years after account closure or for a period as otherwise required under applicable laws.

Security

All user personal information stored by VectorVest is stored on servers at a location designed specifically to ensure that no unauthorized individuals have access to the server or its data. We also have appropriate managerial procedures in place to safeguard the information we collect. The information we collect is entered into our site by you, imported on your instruction and transmitted across the internet to our servers. By using our service, you are consenting to this process. The service providers who host our servers are not permitted to access your personal information except for the purposes of storing it. Although we will take reasonable steps to protect the information you provide to us, you should appreciate that the Internet itself is not secure and take care about the personal information that you transfer over the internet or by email.

User Consent, Waiver and Release

By using the Services, users signify their assent and agreement to this privacy policy and to the collection, use and dissemination of their personal information and data, including to or by third parties, as described herein, and for the purposes and scope described and set forth herein, and you assent and agree to the risks set forth herein and associated with the use and dissemination of your personal information and data, including to third parties. VectorVest may transfer personal data outside the user’s region for certain situations, such as when necessary to perform services provided by VectorVest, for pre-contractual steps or in a user’s interest, or for other business interests that are not overridden by the user’s interests (to the extent permitted by law). By registering for VectorVest Services, a user authorizes VectorVest to transfer their personal data outside the user’s region. If a user does not agree to this policy, or to the collection, use and dissemination of their personal information and data, including to third parties, as described herein, and for the purposes described herein, and/or to the risks set forth herein, he or she should not use the Services, or follow the opt-out procedures identified in section 10 above where consent is relied on.

For EEA, UK and Swiss residents, please see Annex 2 for details on the legal basis on which we rely on to collect your personal data.

BY REGISTERING FOR VECTORVEST SERVICES, AND/OR BY USING THE SERVICES, YOU AND YOUR SUCCESSORS, HEIRS AND ASSIGNS DO HEREBY IRREVOCABLY AND UNCONDITIONALLY WAIVE, TO THE EXTENT PERMITTED BY LAW, RELEASE ACQUIT AND FOREVER DISCHARGE VECTORVEST, INCLUDING ANY AND ALL OF ITS PREDECESSORS, SUCCESSORS, HEIRS, INSURERS, PARENTS, SUBSIDIARIES, DIVISIONS, RELATED COMPANIES, AFFILIATES, ASSIGNS, EMPLOYEES, OFFICERS AND DIRECTORS (HEREINAFTER COLLECTIVELY THE “VECTORVEST RELEASEES”), FROM ANY AND ALL CLAIMS, LIABILITIES, DEMANDS, THREATS, AWARDS, DAMAGES, COSTS, LIABILITIES, ATTORNEY’S FEES, JUDGMENTS, ORDERS AND CAUSES OF ACTION OF WHATEVER KIND OR NATURE, WHETHER NOW KNOWN OR UNKNOWN, WHICH YOU NOW HAVE OR HOLD, OR HAVE AT ANY TIME HERETOFORE HAD OR HELD, OR MAY OTHERWISE IN THE FUTURE WOULD HAVE HELD, AGAINST VECTORVEST AND THE VECTORVEST RELEASEES ARISING OUT OF OR IN CONNECTION WITH OR RELATED OR ANCILLARY TO THE COLLECTION, USE AND DISSEMINATION OF YOUR PERSONAL INFORMATION AND DATA TO OR BY THIRD PARTIES (INCLUDING YODLEE) AS DESCRIBED HEREIN AND WITHIN THE PURPOSES AND SCOPE DESCRIBED AND SET FORTH HEREIN, EVEN IF VECTORVEST IS NEGLIGENT IN PART OR IN FULL IN ANY MANNER IN CONNECTION THEREWITH OR IN CONNECTION WITH THE USE OF THE THIRD PARTY (INCLUDING YODLEE). IN THE EVENT THE FOREGOING WAIVER AND RELEASE IS DEEMED INAPPLICABLE FOR ANY REASON, THEN YOU AGREE AND UNDERSTAND THAT IN NO EVENT SHALL VECTORVEST’S LIABILITY UNDER THIS PRIVACY POLICY, IF ANY, EXCEED THE FEE PAID BY YOU FOR THE SPECIFIC SUBSCRIPTION TERM IN WHICH THE ALLEGED EVENT CREATING LIABILITY AROSE.

“Do Not Track” Disclosure

California and Delaware law require VectorVest to indicate whether it honors “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is not yet a finalized standard, so VectorVest follows the standards set out in this Privacy Policy and does not monitor or respond to Do Not Track browser requests.

Children

VectorVest does not knowingly collect or solicit personal information from anyone under the age of thirteen (or eighteen in the United Kingdom). No one under thirteen years old (or eighteen years old in the United Kingdom) should attempt to register for VectorVest services or send any information to VectorVest. VectorVest will delete any information collected from a child under the age of thirteen (or eighteen in the Unied Kingdom) from our services expediently once it is identified. Should you believe a child has provided us with personal information, call us at (888) 658-7638, write to us at the address above, or email us at: support@vectorvest.com.

Texting Terms and Conditions

By providing your mobile number, checking the opt-in box and clicking "SUBMIT", you consent to receive mobile text alerts from VectorVest Inc. regarding scheduled webinars and other Service and Marketing related matters (message frequency varies depending on number of registrations). You understand that you do not have to sign up for this program in order to make any purchases or subscribe, and your consent above is not a condition of purchase. By signing up, you are confirming you are over the age of 13 (or 18 in the United Kingdom). You understand that we will send mobile text messages using automated technology. Carriers are not liable for delayed or undelivered messages. Message and data rates may apply. Send STOP to 40632 to cancel. Text HELP to 40632 for help. For more information, contact us at support@vectorvest.com or call 1-(888) 658-7638.

Changes to Privacy Policy

If VectorVest changes this privacy policy, we will post those changes at the below sites so that users will always know what information we gather, how we might use that information, and whether we will disclose it to anyone. Continued use of the Services by a user following the posting of changes to these terms will likewise mean the user accepts those changes.

We believe in openness, and we are committed to ensuring that we respect the privacy of those using the exceptional services we provide. If you want to arrange access to your information or have questions about privacy or the use of this site, have feedback for us, or wish to request access, please contact us at support@vectorvest.com.The information provided is intended to be transparent, concise, and understandable. If you have any questions or complaints regarding this policy, you may also contact: Ms. Linda Royer, Chief Executive Officer, VectorVest, Inc. 2650 W. Market Street, Akron, OH 44333 e. lindar@vectorvest.com p. (330) 867-2814, ext. 502 f. (216) 803-0880.

Revision Date: 3 May 2024

Annex 1 – Privacy information specific to Australian residents.

VectorVest Inc (ARBN 654 498 218) is committed to protecting your privacy and abides by Australia’s Privacy Principles and the Privacy Law. If you need to know more, we are more than happy to explain to you what sort of personal information we hold, for what purposes, and how we collect, hold, use and disclose that information. Should you require additional information about the Australian Privacy Principles, the Privacy Law or our obligations you can also access the website of The Office of the Australian Information Commissioner (http://www.oaic.gov.au/).

Although we will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date, it is your responsibility to ensure that the information you provide to us is accurate, complete and current. You control the information you provide to us and you can correct or update any information you choose to provide to us. If you want us to correct our records simply tell us what needs to be changed and why.

Unless you choose to provide or disclose your personal information, or instruct us to do so, the personal information we hold will be secured on our servers and not be transferred elsewhere. There are some exceptions, but we won’t transfer personal information to a foreign country unless:

we believe that the recipient of the information is subject to a law or arrangements that are substantially similar to the Australian Privacy Principles; or
you consent to the transfer; or
the transfer is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures taken in response to your request; or
the transfer is necessary for the conclusion or performance of a contract concluded by you.

We will not transfer information contrary to this policy or without your consent or in a manner inconsistent with the Australian Privacy Principles.

Annex 2 – Privacy information specific to EEA, UK and Swiss residents.

VectorVest is committed to ensure compliance with all applicable data protection legislation including:

UK Data Protection Legislation: all applicable data protection and privacy legislation in force from time to time (as amended) in the UK including without limitation the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder) (DPA 2018); the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended; and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data. “UK GDPR” means as defined in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.
EU Data Protection Legislation: all applicable data protection and privacy legislation in force from time to time (as amended) in the EU including without limitation GDPR; the Privacy and Electronic Communications Regulations 2003 as amended; and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data. “EU GDPR” means the General Data Protection Regulation ((EU) 2016/679)
Swiss Data Protection Legislation: all applicable data protection and privacy legislation in force from time to time (as amended) in Switzerland including without limitation Swiss Civil Code and Federal Act on Data Protection 1992 and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data.

Use of Personal Information:

We will only use your personal data when the law allows us to, and we are required by law to have a lawful basis for processing personal data. In particular, at least one of the following must apply whenever we process personal data:

Performance of Contract: We will process your personal data where we need to in order to perform the contract we are about to enter into or have entered into with you.
Legitimate Interests: We will process your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. “Legitimate Interest” means our interest in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal Obligations: We will process your personal data where it is necessary for compliance with a legal obligation in the EEA, UK or Switzerland that we are subject to.
Vital Interest: We will process your personal data where it is necessary to protect someone’s life.
Public Task: We will process your personal data where it is necessary to perform a task in the public interest and the task has a clear basis in law.
Consent: where you expressly agree to us processing your personal data. You have the right to withdraw consent at any time by contacting us.

Special Category Personal Data: Where we process any “special category personal data”, in addition to one of the legal bases noted above, we also need that we have a further legal basis for such processing.

This will most commonly be one of the following:

Explicit Consent: Where you have given us your explicit consent to the processing;
Vital Interests: The processing is necessary to protect your vital interests or those of another natural person where you are physically or legally incapable of giving consent;
Made public by the data subject: Processing relates to personal data that you have made public;
Legal claims and judicial acts: The processing is necessary for the establishment, exercise or defence of legal claims; or
Substantial public interest: The processing is necessary for reasons of substantial public interest (e.g. regulatory requirements, preventing or detecting unlawful acts).

When we refer to “special category personal data”, we mean personal data that reveals racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, sex life or sexual orientation of an individual.

Purpose and Lawful Basis:

Purpose/Activity	Type of Data	Lawful Basis for Processing
To register you as a new user/customer.	Identity data, contact data, financial data, usage data, and communication data, and account data.	Performance of a contract with you
To deliver services to you.	Identity data, contact data, financial data, usage data, and communication data, and account data.	Performance of a contract with you
To deliver relevant Website content to you and measure or understand the effectiveness of the content we provide to you	Identity data, contact data, financial data, usage data, and communication data, account data, social media data, and location data.	Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our business strategy)
To process and manage payments, fees and charges and collect or recover money owed to us	Identity data, contact data, financial data, usage data, and communication data, and account data.	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and ensure the proper functioning of the Website)
To manage our relationship with you which will include notifying you about changes to our terms and conditions or privacy policy, and/or asking you to leave a review or take a survey	Identity data, contact data, communication data, and account data.	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use our services)
To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity data, contact data, usage data, communication data, and account data.	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, services, and user relationships and experiences	Technical data, location data, and usage data.	Necessary for our legitimate interests (to define types of users for our services, to keep our website updated and relevant, to develop our business and to inform our business strategy)

Rights under EU, UK and Swiss Data Protection Legislation:

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data. You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent. You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Third Parties and International Transfers:

We require all third parties (including Yodlee) to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer your personal data outside of the UK, for example where our external third-party suppliers (such as hosting, IT, security, support, billing, marketing and communications e.g. Salesforce and Yodlee) are located. Whenever we transfer your personal data out of the UK, EEA or Switzerland we ensure a similar degree of protection is afforded to it by:

ensuring we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (including Standard Contractual Clauses for EEA and Switzerland or the UK International Data Transfer Agreement / UK Addendum for UK); or
putting in place specific contracts approved for use which give personal data the same protection it has in either the EEA, UK, or Switzerland (as applicable).

Please contact us if you want further information on the specific mechanism used by us for international transfers (see contact us section above).

Complaints:

VectorVest commits to resolve complaints about your privacy and our collection or use of your personal information. European Union, UK or Swiss individuals with inquiries or complaints regarding this privacy policy can contact VectorVest via: Call us at +1 (888) 658-7638, write to us at the address below, or email us at support@vectorvest.com. We will try to provide a response within 5 days and to investigate and attempt to resolve your complaint within 20 days.

You have the right to make a complaint at any time to any regulatory body, including the Information Commissioner’s Office (the UK regulator for data protection issues), individual supervisory authorities for member states in the EU, or Federal Data Protection and Information Commissioner (the Swiss regulator for data protection issues). We would, however, appreciate the chance to deal with your concerns before you approach a regulatory body so, please contact us in the first instance.

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), VectorVest commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact VectorVest via phone +1 (888) 658-7638, via email at to us at support@vectorvest.com, or via letter, email or phone to Ms. Linda Royer, Chief Executive Officer, VectorVest, Inc. 2650 W. Market Street, Akron, OH 44333 e. lindar@vectorvest.com p. (330) 867-2814, ext. 502 f. (216) 803-0880. VectorVest has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you. If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

The United States Federal Trade Commission has jurisdiction over VectorVest’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

If your complaint involves human resources data transferred to the United States from the European Union, the United Kingdom, or Switzerland in the context of the employment relationship, and VectorVest does not address it satisfactorily, VectorVest commits to cooperate with the panel established by the EU data protection authorities (DPA Panel), the UK Information Commissioner’s Office, and the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel, ICO, or FDPIC, as applicable, with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Contact details for the EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en. Complaints related to human resources data should not be addressed to the BBB NATIONAL PROGRAMS.

Revision Date: 5/3/2024