LAST UPDATED: August 14, 2024
| FACTS | WHAT DOES iCAPITAL DO WITH YOUR PERSONAL INFORMATION? |
| Who? | This policy explains how iCapital collects, uses, and discloses personal information relating to investors or potential investors in financial products and/or services made available by or through iCapital. |
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include: ■ Email, phone number, address and other personal identifiers ■ Social Security number, place and date of birth, and passport information ■ Tax information, bank account details, source of funds, and details related to your investment activities |
| How? | All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons iCapital chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does iCapital share? | Can you limit this sharing? |
| For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes— to offer our products and services to you | Yes | Yes |
| For joint marketing with other financial companies | Yes | Yes |
| For our affiliates’ everyday business purposes— information about your transactions and experiences | Yes | No |
| For our affiliates’ everyday business purposes— information about your creditworthiness | No | We don’t share |
| For our affiliates to market to you | Yes | Yes |
| For nonaffiliates to market to you | With your consent | Yes |
| To limit our sharing | ■ (Call) 212.994.7400; ■ (Email) [email protected]; ■ (Mail) iCapital, ATTN: Privacy, 60 East 42nd Street, New York, NY 10165.Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to request that we limit our sharing. |
| Questions? | Email [email protected] |
| Mail-in Form | |||
| Mark any/all you want to limit: □ Do not use my personal information to market to me. □ Do not share my personal information with other financial institutions to jointly market to me. □ Do not allow your affiliates to use my personal information to market to me. □ I revoke my consent to your sharing of my personal information with nonaffiliates to market to me. |
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| Name | Mail to: Institutional Capital Network, Inc. ATTN: Privacy Team 60 East 42nd Street, New York, NY 10165 |
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Who we are |
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| Who is providing this notice? | Institutional Capital Network, Inc., and our affiliates, including certain affiliates that are registered investment advisers and registered broker-dealers as detailed on https://icapital.com/certain-icapital-entities/ (collectively, “iCapital”). |
What we do |
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| How does iCapital protect my personal information? | To protect your personal information from unauthorized access, we use security controls that comply with applicable law. These controls include commercially reasonable technical and organizational safeguards designed to protect customer information. |
| How does iCapital collect my personal information? | We collect your personal information when you engage or use our Site or Services, for example, when you: ■ register to use our Services ■ contact us for assistance ■ use or access our Site. We also collect your personal information from other companies, such as affiliates, data aggregators and other financial institutions. Pursuant to applicable United States federal law, you have the right to limit the sharing of personal information in the following circumstances: when information about your creditworthiness is being shared with affiliates for their everyday business purposes, and when your personal information is being shared with affiliates and non-affiliates for their own marketing purposes. Please note that we do not share information about your creditworthiness with our affiliates for their everyday business purposes. We share your personal information with non-affiliates for their own marketing purposes only with your consent, which you may revoke at any time. Other laws may furnish you additional rights to limit sharing of your personal information. See below for more information on your rights under certain state laws. |
| Why can’t I limit all sharing? | Federal law gives you the right to limit only ■ sharing for affiliates’ everyday business purposes – information about your creditworthiness ■ affiliates from using your information to market to you ■ sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law. |
| What happens when I limit sharing for an account I hold jointly with someone else? | Your choices will apply to everyone on your account, unless you tell us otherwise. |
Definitions |
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| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with the iCapital name, and other branding, such as iCapital Advisors, LLC, iCapital Markets, LLC and Mirador, LLC. |
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies. |
| Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial institutions or other institutions that partner with us to provide the iCapital platform to their customers. |
| Services | The online services that are available via our Site or are otherwise provided by iCapital without use of our Site to select customers and their authorized users who have registered to receive such services and agreed to certain contractual terms with iCapital. |
| Site | Any website, application, or online platform owned, licensed, or operated by iCapital, including icapital.com, s.icapitalnetwork.com/, and simonmarkets.com. |
Other important information |
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| Do-Not-Call Policy: iCapital seeks to comply with all federal and state regulations on telephone usage, including the maintenance of an internal do-not-call (DNC) list. Consumers who ask to be included on iCapital’s internal DNC list will be removed from future telephone marketing campaigns. This opt-out will remain in effect unless and until the consumer opts back in to receive such communications.
Nevada: We are providing this notice under state law, which requires that we provide Nevada residents with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101; Phone: 702.486.3132; Email: [email protected]. If you prefer not to receive marketing calls from iCapital, you may be placed on our internal DNC list. Vermont: Under Vermont law, we will not share information we collect about Vermont residents with non-iCapital entities without your consent, unless otherwise permitted by law. We also will not share information on your creditworthiness with affiliates without your consent. Note that the preceding sentence does not cover information about transactions or experiences, which information may be shared with affiliates without your consent. Other Information: If, at any time, you provide iCapital with contact numbers that are wireless telephone numbers, including, but not limited to, cell or VoIP numbers, you are consenting to iCapital using an automated dialing system to call or text you, or sending prerecorded messages to you, in order to service, and collect on, any iCapital personal or business accounts for which you are an authorized signer, guarantor or designated contact person, but you are not consenting to iCapital marketing to you. By providing your email address, you consent to receive service-related notices and disclosures via electronic mail from iCapital. |
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