ICAPITAL PORTFOLIO INTELLIGENCE PRIVACY POLICY

LAST UPDATED: Mar 21, 2022

Choice and Rights. 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.

Types of Personal Information. The personal information we collect and share depends on the product or service you have with us. For our Portfolio Intelligence platform, this information generally includes: (i) customer names (first, last, middle), (ii) account usernames, and (iii) platform usage data.

Reasons for Sharing Personal Information. We need to share customers’ personal information to run our everyday business. In the section below, we list the reasons financial companies can share customers’ personal information, the reasons we do so, and whether you can limit this sharing.

REASONS WE CAN SHARE YOUR PERSONAL INFORMATION

• Financial companies may share personal information for their everyday business purposes, such as to process your transactions, maintain your account, conduct portfolio analysis, respond to a legal order, or report to credit bureaus.
• Do we share personal information in this manner? Yes
• Can you limit this sharing? No
• Financial companies may share personal information for their marketing purposes, such as to offer products and services to you.
• Do we share personal information in this manner? Yes
• Can you limit this sharing? No
• Financial companies may share personal information to undertake joint marketing with other financial companies.
• Do we share personal information in this manner? No
• Can you limit this sharing? N/A
• Financial companies may share personal information for their affiliates’ everyday business purposes - information about your transactions and experiences.
• Do we share personal information in this manner? Yes
• Can you limit this sharing? No
• Financial companies may share personal information for their affiliates’ everyday business purposes - information about your creditworthiness.
• Do we share personal information in this manner? No
• Can you limit this sharing? N/A
• Financial companies may share personal information for their affiliates and non-affiliates to market to you.
• Do we share personal information in this manner? No
• Can you limit this sharing? N/A

HOW YOU CAN LIMIT THE SHARING OF YOUR PERSONAL INFORMATION

We currently do not share any customer's personal information in a manner that requires that the customer be allowed to limit the sharing of personal information. In the event we change our information-sharing practices, we will provide customers notice of the change. If you have any questions or concerns about our information-sharing practices, please contact us at the following: (call) 212.994.7400; (email) [email protected]; (write) iCapital, ATTN: Privacy, 60 East 42nd Street, New York, NY 10165.

WHO WE ARE AND HOW WE PROTECT PERSONAL INFORMATION

Institutional Capital Network, Inc. is the parent company of iCapital Advisors, LLC and owns Portfolio Intelligence (collectively, “iCapital”). To protect your personal information from unauthorized access, we use security controls that comply with applicable law. These controls include technical, physical, and administrative safeguards designed to protect customer information.

COLLECTING PERSONAL INFORMATION AND LIMITING SHARING

We collect your personal information when you engage or use our services, for example, when you undertake any of the following: (i) registering to use our services, (ii) contacting us for assistance or otherwise engaging with us, or (iii) using or accessing our services or websites. 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. 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 and local law.

WHAT HAPPENS WHEN I LIMIT SHARING ON A JOINT ACCOUNT?

Your choices will apply to everyone on your account, unless you tell us otherwise.

DEFINITIONS

• Affiliates are 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 Portfolio Intelligence and AI Insight.
• Non-Affiliates are companies not related by common ownership or control. They can be financial and nonfinancial companies. iCapital does not share customer information with non-affiliates.
• Joint Marketing occurs when non-affiliated financial companies work together, pursuant to an agreement, to market financial products or services to you. iCapital does not have joint marketing arrangements with other companies.

OTHER IMPORTANT INFORMATION

• 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.
• California: Under California law, we will not share information we collect about California residents with companies outside iCapital unless we have your consent or the law allows.
• 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 Privacy Rights: For information on our compliance with other data protection laws, including the California Consumer Privacy Act (CCPA), please visit our website privacy policy.
• 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. For any type of phone calls with iCapital, you consent that the call may be monitored or recorded for quality control, training purposes, and other lawful business purposes. By providing your email address, you consent to receive electronic mail from iCapital.