Privacy Policy

1. Scope

This Privacy Policy explains how Investor Services and, in connection with custody accounts, Institutional Trust Company (together, “we”) handle personal information collected through the Services and the account relationship. It also serves as our privacy notice under applicable U.S. federal financial-privacy law and California law.

2. Information we collect

We collect: (a) information you provide — name, contact details, and details you submit in forms, applications, or communications; account, beneficiary, and tax information (including taxpayer identification numbers) where you open or maintain an account; (b) information collected automatically — device, browser, IP address, pages viewed, and similar usage data via cookies and similar technologies (see our Cookie Policy); and (c) information from third parties — identity-verification, fraud-prevention, and service providers, and, for accounts, sponsors, issuers, or transfer agents as needed to administer holdings.

3. How we use information

We use information to: operate and secure the Services; respond to inquiries and route form submissions; open, administer, and service accounts; process transactions you direct; perform identity verification, fraud prevention, and anti-money-laundering and sanctions screening; produce statements and tax reporting; comply with law and legal process; and improve the Services. We do not sell your personal information.

4. Financial-privacy notice

For account relationships, we handle nonpublic personal information consistent with the Gramm-Leach-Bliley Act and its implementing rules. We share such information only as permitted by law — for example, to process and service your account, with your service providers at your direction, with our own service providers under confidentiality obligations, and as required by regulators or legal process. We do not share nonpublic personal information with nonaffiliated third parties for their own marketing.

5. How we share information

We may share information with: service providers and processors (including our security and platform providers, B5 Secure™ and A8 Core™) bound by confidentiality; the custodian, transfer agents, sponsors, and issuers to administer holdings you direct; professional advisers you authorize; regulators, law enforcement, and parties to legal process as required; and a successor in a merger or transfer, subject to this Policy. We do not sell or “share” personal information for cross-context behavioral advertising.

6. Cookies and analytics

We use strictly necessary and, where enabled, functional and analytics cookies. See the Cookie Policy for details and choices, including how to manage cookies and how we respond to browser signals.

7. Data retention

We retain personal information for as long as needed to provide the Services and to meet legal, tax, regulatory, accounting, and recordkeeping obligations (which, for financial accounts, may extend several years after an account closes), after which we delete or de-identify it.

8. Security

We protect information using per-record authorization, tokenization of sensitive data, encryption in transit, and a tamper-evident audit trail, as described in our Security Policy. No system is perfectly secure; we cannot guarantee absolute security.

9. Your California privacy rights

If you are a California resident, subject to the California Consumer Privacy Act (as amended by the CPRA), you may have the right to: know and access the personal information we have collected; delete personal information; correct inaccurate information; and opt out of the “sale” or “sharing” of personal information and limit use of sensitive personal information (we do not sell or share as defined). You will not be discriminated against for exercising these rights. Certain information subject to the GLBA is exempt from the CCPA. To exercise rights, contact privacy@investorservices.com; we will verify your request, and you may use an authorized agent. California’s “Shine the Light” law: we do not disclose personal information to third parties for their direct marketing.

10. Children

The Services are not directed to children under 16, and we do not knowingly collect their personal information.

11. Changes

We may update this Policy by posting a new version with a revised effective date; material changes will be reasonably notified.

12. Contact

Privacy questions or requests: privacy@investorservices.com, or write to Investor Services, PO Box 1410, Menlo Park, California 94026-1410.

Questions about these terms: legal@investorservices.com. Institutional Trust Company · +1 (605) 205-2500.

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