Vectis Capital Privacy Policy

Information We Collect

The types of personal information Vectis Capital collects depend on the products and services a client holds with the firm. This may include name, age, address, and Social Security number; income, account balances, and debt; and financial goals, spending habits, and other information related to a client's financial condition. Such information is gathered, for example, when an account is opened and account documentation is completed.

Visitors to this site are not required to provide personal information. The site uses privacy-conscious, first-party analytics to understand aggregate page visits and interactions. Analytics events do not include mobile numbers, message contents, or other information entered into forms. The site does not employ advertising technologies.

How Information Is Used

Personal information is used to provide investment advisory services, to administer accounts, to satisfy legal and regulatory obligations, and to communicate with clients regarding their relationship with the firm.

Sharing of Information

All financial companies need to share customers' personal information to run their everyday business. Vectis Capital shares personal information for its everyday business purposes — such as processing transactions, maintaining accounts, and responding to court orders and legal investigations — for its own marketing purposes, and with its affiliates for their everyday business purposes, limited to information about transactions and experiences.

The firm does not engage in joint marketing with other financial companies, does not permit affiliates to market to clients, does not permit non-affiliates to market to clients, and does not sell client information.

Limits on Sharing

Federal law gives consumers the right to limit some, but not all, sharing — specifically, the use of information by affiliates to market to you and sharing with non-affiliates for their marketing purposes. State laws and individual companies may provide additional rights to limit sharing. Clients may contact the firm at any time to limit its sharing.

For jointly held accounts, a client's choices apply to everyone on the account unless the firm is told otherwise.

Mobile Messaging Privacy

Mobile phone numbers, SMS opt-in data, and consent records are not sold, rented, or shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.

This mobile-specific restriction controls with respect to SMS opt-in data and consent records, notwithstanding any broader description of information sharing elsewhere in this policy, including the Regulation S-P disclosures above.

Your Rights

Clients have the right to request access to the information collected about them, including the purposes for which it is collected and the third parties and service providers with which it is shared, and to correct information that is inaccurate or incomplete.

Clients have the right to request, in certain circumstances, the deletion of information collected directly from them. Where the law provides a reason the firm cannot comply, or may comply only in a more limited way, that reason will be explained in the firm's response.

Clients have the right to opt out of any sale of their information to third parties, of targeted advertising, and of profiling in furtherance of decisions that produce legal or similarly significant effects. Vectis Capital does not sell information, does not utilize targeted advertising, and does not engage in such profiling.

If the firm declines to act on a request, clients may ask that the decision be reconsidered within 45 days of receiving the firm's response.

Privacy Notice Under Regulation S-P

In accordance with Regulation S-P adopted by the U.S. Securities and Exchange Commission, Vectis Capital maintains policies and procedures reasonably designed to safeguard client records and information. To protect personal information from unauthorized access and use, the firm employs security measures that comply with federal law, including computer safeguards, secured files, and secured facilities. Former clients receive the same protections as current clients.

Contact

Questions regarding this policy may be directed to Vectis Capital by telephone at (972) 777-1319, or in writing to 3723 Greenville Ave STE 80164, Dallas, TX 75206. Clients receive the firm's full privacy notice upon establishing a relationship and annually thereafter.