Updated: July 5, 2021

Privacy Policy

Welcome to the web site (the “Site”) of Iconik Securities, Inc. (“iconik”, "Iconik", “we”, “us” and/or “our”). This Site is operated by Iconik and has been created to provide information about our company, mobile applications and related services (together with the Site, the “Services”). This Privacy Policy (the “Privacy Policy”) sets forth Iconik’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and users of the Services (the “Visitors”, or individually, “Visitor”, “you”, and/or “your”). Any discussion of your use of the Service in this Privacy Policy is meant to include your visits and other interactions with the Site and Services, whether or not you are a user of Iconik’s trading-related products.

By using the Services, you do hereby warrant and represent that:

• You have read, understood, and agreed to all terms and conditions stated herein;
• You are giving Iconik permission to use and store such information consistent with this Privacy Policy.

Types of information collected

Personal information you provide through the Services

iconik collects and utilizes certain information through the Services in order to provide the Services to you. For example, your financial information may be used to execute orders you submit through the Services for execution. Through the services, the following information may be collected:

• Identity Information: includes your full name, date of birth, gender, social security numbers, and other data on government-issued identification documents.
• Contact Information: includes your email address, mailing address, and telephone numbers.
• Financial Information: includes your bank account and payment card details, suitability information, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores.
• Profile Information: includes your username and password, purchases or orders made by you, your knowledge assessment results, and your interests, preferences, feedback, and survey responses.
• Usage Information: includes information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, photos or media you upload to the Services, your username, and other content you provide (“Usage Information”). Please remember that Iconik may, but has no obligation to, monitor, record, and store Usage Information in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, to protect and defend our rights and property, or for other reasons relating to our provision of the Services. By using the Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes.
• Information pertaining to any voting agreement you may have entered into utilizing the Services.
• Additional Information includes information that you submit via job applications, customer support, or other similar means. We may also collect any communications between Iconik and you (including recording calls made to or by Iconik) and any other information you provide to Iconik.

Personal Information Collected Automatically

As is true of many digital platforms, we collect certain personal information automatically when you visit our online services, including:

• Location Data. Our Service may collect your approximate location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Service (“Location Data”), and to allow Iconik to better understand where the users of its services are approximately located.
• Usage and Device Data Collected Automatically Through Tracking Technologies. To provide a personalized and enhanced user experience, we, and our third-party partners, automatically collect certain types of usage information when you visit or use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location identifying technologies, file information, and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information. We use Tracking Technologies to help ensure that you have a high-quality experience on our Services, for example, by adapting our Service to be compatible with your device or operating system, among other things. You may change or disable certain cookie settings in your browser. However, doing so may limit the features available to you through the Services.
• Account Linking. Iconik offers account linking and aggregation services ("Linking Services") through Plaid Inc. ("Plaid"). By utilizing these Linking Services, you acknowledge and agree that the terms of Plaid's Privacy Policy (currently located at https://plaid.com/legal/#end-user-privacy-policy ) will govern Plaid's use of such information, and you expressly agree to the terms and conditions of Plaid's Privacy Policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide the Linking Services to you.
• Third Party Services. If you link, connect, or log in to your Iconik Account with a third-party service (e.g. Google, Apple), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• Google Analytics. We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service.

Use of your information

We use and process the information we collect for purposes described in this Privacy Policy or as otherwise described to you on our Services or in connection with our Services. For example, we use your information to:

• Create and process your account and deliver the Services to you, including to allow you to register for the Services and participate in interactive features and for Iconik to authenticate your identity, provide billing and account management, and complete other administrative matters;
• Send you transactional information, including confirmations, invoices, technical notices, product and services information and announcements, software updates, security alerts, support and administrative messages, and information about your transactions with us;
• Communicate with you such as to respond to your comments and questions, deliver newsletters or other content we believe you will be interested in, provide customer service or feedback, conduct surveys, respond to employment opportunities for which you’ve applied, notify you about upcoming events, or for any other purposes in connection with the Services;
• Provide you with updates about products and services offered by us and our partners;
• Make suggestions and recommendations to you;
• Monitor, administer, and enhance our Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• Enhance the safety and security of our Services, business, and users, and investigate or provide notice of fraud or unlawful or criminal activity;
• Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
• Comply with applicable laws and legal obligations.

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the personal information we collect. We may share your personal information in the instances described below.

• Authorized third-party vendors and service providers. We share personal data with certain authorized and vetted contractors, sub-processors, subcontractors, third-party vendors, and service providers who help us run and protect our business. This includes sending emails, conducting business analytics, marketing, and data processing.
• Companies in which you hold securities. We may provide your name, address, and securities positions to requesting companies in which you hold securities.
• Iconik affiliates. We share personal data with other companies owned or controlled by Iconik Securities, Inc, for example, in order to execute orders that you have requested.
• Legal purposes. We disclose personal data to respond to subpoenas, court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Iconik, our affiliates, users, or the public.
• Third parties you have requested we share your information with. We share limited personal data with third parties to facilitate certain requests you have made through the Service, such as opting into a third party's mailing list. In these situations, we endeavor to only share the minimum amount of information required to honor your request.
• With your consent. We share personal data for any other purposes disclosed to you with your consent. We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

Links to other websites

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Iconik (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Iconik endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Your choices

You can visit the Site without providing any Personal Data yourself. If you choose not to provide any Personal Data, you may not be able to use certain Services. You may also opt out of receiving communications from us, remove your information from our database, and choose not to receive future communications unrelated to the Services (such as those about your account, transactions, servicing, or Iconik’s ongoing business relations) by cancelling your account; which you can do by contacting Iconik at [email protected] Further, if you use any Services, we may occasionally contact you with information about special events, sales, activities, promotions, contests, submission opportunities, and programs. You always have the option to ask Iconik not to contact you with this information again. If you receive unsolicited email from an Iconik domain, please contact us at [email protected]

For California residents

California Civil Code Section 1798.83 permits Site users who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make a request, please contact us: [email protected]

Furthermore, California residents have the following rights with respect to Personal Data we may have collected about them:

(i) Requests to Know

You have the right to request that we disclose: The categories of Personal Data we have collected about you; the categories of Personal Data about you we have sold or disclosed for a business purpose; the categories of sources from which we have collected Personal Data about you; the business or commercial purposes for selling or collecting Personal Data about you; the categories of Personal Data sold or shared about you, as well as the categories of third parties to whom the Personal Data was sold, by category of Personal Data for each party to whom Personal Data was sold; and the specific pieces of Personal Data collected.

You may submit a Request to Know by email to [email protected] The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

(ii) Requests to Delete

You have the right to request that we delete any Personal Data about you that we have collected. Upon receiving a verified request to delete Personal Data, we will do so unless otherwise authorized by law. You may submit a request to delete Personal Data by email to [email protected]

(iii) Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

(iv) Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request to know and requests to delete Personal Data about you via: [email protected]

Upon receipt of a request and in order to protect your privacy and the security of Personal Data about you, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

(v) The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.

VISITORS OUTSIDE OF THE U.S.

Important Information for Visitors Outside of the U.S. – Transfer of Data. We primarily store data about you, including Personal Data, on servers located and operated within the United States. If you reside outside of the United States, in order to provide and operate the Site and Services, we may send and store your Personal Data outside of the country where you reside or are located, to the United States. Therefore, our collection and use of your Personal Data is subject to the United States’ laws related to privacy and use of personal data and information. These laws, including what is determined to be “personal data and/or information,” are different and may be less protective than those applicable to you in your country of residence. By accepting the terms of this Privacy Policy, you acknowledge, agree and consent to (1) the transfer to and processing of personal information on servers located outside of the country where you reside, (2) our collection and use of your personal information as described herein and in accordance with the laws of the United States that may be different and may be less protective than those in your country and (3) that you are taking a risk by using the Site and Services.

Children

We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at [email protected]

Changes to this policy

This Privacy Policy will evolve with time, and when we update it, we will revise the "Updated" date above and post the new Policy. To stay informed of our privacy practices, we recommend you review the Policy on a regular basis as you continue to use our Services.

How to contact us

If you have any questions about this United States Privacy Policy or the Services, please contact us at [email protected]