Privacy Policy

EquityMatch privacy policy 

This privacy policy describes EquityMatch's collection, use, handling and sharing of personal information. As used in this privacy policy, “Fusion” refers to EquityMatch Brokerage Services LLC and the other EquityMatch companies that offer products and services available through this website (www.fusiontrade.org) (Website), the EquityMatch self-directed trading portal and contracts where this policy appears. 

EquityMatch("we") may offer products, services and digital offerings that may have a different or additional privacy policies made available to You if you choose to use those products, services or digital offerings. Some products and services available on our Digital Properties may have supplemental privacy policies that pertain to those products and services. 

As used in this privacy policy ("policy"), personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. 


Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy. Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether EquityMatch provides services to your employer or plan sponsor. 


This policy is reviewed annually and updated to reflect any changes.

How and why we obtain and use personal information 

EquityMatch recognises the importance of maintaining personal information about you and when we use it, we do so with respect for your privacy. We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; operate and manage our business; and fulfil legal and regulatory requirements. EquityMatch collects public and non-public personal information from customers and visitors from various sources. 


Some examples include: 

• You or your representative on applications or forms (for example, when you interact with our customer service staff, and when you visit our websites or use our applications) 

• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our websites) 

• You or your employer or plan sponsor if EquityMatch provides them with record-keeping and/or employee benefits advisory services (for example, payroll, human resources, or benefits information) 

• Transactional activity in your account (for example, trading history and balances) 

• Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products) 

• Information from other third-party sources (for example, to verify your identity and to better understand your product and service needs) 

• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into EquityMatch )


Please note that information by which you cannot be identified (for example, anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.

Examples of other personal information we collect and hold include: 

  • name;
  • date of birth; 
  • residential address; 
  • email address; 
  • cryptocurrency wallet ID, address and transactions; 
  • mobile phone number; 
  • copies of, or details from, identification documents;
  • the purpose of your cryptocurrency transactions and source of funds; 
  • if relevant, politically exposed persons match results; and 
  • qualifications and employment history, in the event you are applying for a job or contract with us.

    We may also collect other personal information we consider is reasonably necessary for one or more of our functions and activities such as personal information that we request from you or that you or a third party provide to us, and which we are authorised or required by law to collect.

    Sensitive information
    We may also collect sensitive information about you if you consent to us doing so and the information is reasonably necessary for one or more of our functions or activities, or where otherwise permitted or required by law.  The kinds of sensitive information that we collect and hold about you depends on your dealings with us. Examples of sensitive information we collect and hold include biometric data, or information on your racial or ethnic origin which may be included in your identification documents.


  • Where we collect sensitive information, we will only process it: 
  • to verify your identity; 
  • to perform a contract with you or to carry out our business in relation to that contract;  
  • where we have legitimate interests to process the personal data and they’re not overridden by your rights; 
  • in accordance with a legal obligation; or 
  • where we have your consent.
    We will retain your information only for as long as is necessary for the purposes set forth in this Privacy Policy, for as long as your account remains active, or as needed to provide you with any services you request from us. We will retain and use your information to the extent necessary to comply with our legal obligations. 


How we protect information about you 

We implement and maintain physical, administrative, technical and organisational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology. At EquityMatch , we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you and to operate our business.


Who we share your Personal Information with, and in what circumstances 

We share your Personal Information in the following circumstances: 

  • We may share your Personal Information between the EquityMatch Entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. A list of the countries in which EquityMatch Entities are located can be found on our website; 
  • We instruct service providers within and outside of EquityMatch (including cloud service providers such as AWS), domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and in accordance with our instructions and based on our legitimate interest to provide, maintain and improve our products and services. For example, if you choose to subscribe to any services provided by a third-party provider listed on an Interactive Brokers Investors' Marketplace, we may disclose such information to service providers as necessary for them to provide the services that you have requested. EquityMatch generally requires these service providers to enter into confidentiality agreements with EquityMatch that limit their use of the information that they receive. Such agreements prohibit the service provider from using EquityMatch client information that they receive other than to carry out the purposes for which the information was disclosed. If required by law, EquityMatch will retain control over and will remain responsible for your Personal Information and will use appropriate safeguards to ensure the integrity and security of your Personal Information when engaging service providers; 
  • We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies; 
  • We may disclose information about you to any depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the provision of our services or establishing a relationship with a view to such transactions;  
  • We may share data provided to us for employment applications with third parties to assist us with the conduct of our recruitment processes; 
  • Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;  
  • We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services. Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so, when we are allowed or required by applicable law or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.



Your digital privacy

When you interact with us by using our websites, online services or applications (including mobile apps) that are owned and controlled by EquityMatch Investments ("our digital offerings"), or via electronic communications, EquityMatch manages personal information in accordance with all of the practices and safeguards described in this policy. When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical, and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience. Additionally, the following policies and practices apply when you are online.



Cookies and similar technologies 

EquityMatch and our third-party service providers may use cookies and similar technologies ("cookies") to support the operation of and maintain our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. EquityMatch cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout. Both EquityMatch and third-party service providers we hire, such as Google, Meta and Microsoft, may use cookies and other technologies, such as web beacons, tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings, to improve the effectiveness of our online advertising and to understand more about the demographics of our users. You can learn more about Google's practices with Google Analytics by visiting Google's PrivacyPolicy. You can also view Google's currently available OPt-out Options.


Advertising on EquityMatchDigital Offerings 

EquityMatch advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about EquityMatch and third-party products and services that may be of interest to you. We may also use third-party service providers to help us determine which EquityMatch products and services may be of interest to you. These service providers may collect information about your activity on EquityMatch digital offerings using cookies and other technologies to analyze, for example, pages visited, search engine referrals, browsing patterns and responses to advertisements and promotions. Such service providers may only collect and use such information for purposes specified by EquityMatch and not for their own purposes. Advertising on Non-EquityMatchDigital Offerings EquityMatch also advertises our products and services on digital offerings not affiliated with EquityMatch and we contract with third-party advertising companies, such as Meta, to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, pages visited, and time stamp. 


EquityMatch and these third-party online advertising companies may use the data collected, along with other information we have about you and your EquityMatch relationships, to serve relevant ads to you and to measure the success of our advertising campaigns. The advertisements may be relevant to your interests, as determined by your activity on EquityMatch and non-EquityMatch websites. These are known as "interest-based advertisements". 


You may opt-out of receiving interest-based advertisements from online advertising companies, including those used by EquityMatch, by clicking on the AdChoices icon and following the opt-out instructions.

If you generally want to "opt out" of receiving on line interest-based advertisements on your internet browser from advertisers and third parties that participate in a self-regulatory programs like the Digital Advertising Alliance (DAA) program or the Network Advertising Initiative (NAI), please follow the instructions at WebChoices: Digital Advertising Alliance's Consumer Choice Tool for Web US (aboutads.info). and NAI Consumer OPt Out.(networkadvertising.org). to place an "opt-out" cookie on your device indicating that you do not want to receive interest-based advertisements. If you want to "opt out" of receiving online interest-based advertisements on mobile devices, please follow the instructions at YourAdChoices.com IARP-Choices and Mobile OPt Out - NAI: Network Advertising Initiative (thenai.org).



Children's privacy 

In general, EquityMatch's digital offerings are not directed to individuals under the age of thirteen (13). EquityMatch does not intentionally collect information on EquityMatch websites from those we know are under 13, and we request that these individuals do not provide personal information through our digital offerings. If we do provide a digital offering that is intended to be used by individuals under the age of thirteen, it will have a separate privacy policy.


Additional information 

If you are a former customer, this policy also applies to you; we treat your information with the same care as we do information about current customers. EquityMatch offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or our digital offerings. You may also write or call us with your request for information. If you transact business through EquityMatch's life insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.


Additional Information for California Residents 

This section is provided for purposes related to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA") and applies solely to the personal information and EquityMatchcompanies that are subject to the CCPA. As used in this section, "personal information" means information that meets the definition of "personal information" as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA.


EquityMatch companies and the CCPA

Depending on the EquityMatch company with which you have a relationship or otherwise interact, the nature of your relationship and interactions with that EquityMatch company, and the products and services provided to you through that relationship, some or all of the personal information that the EquityMatch company collects or maintains is covered by one or more of the exemptions described below (see the section below entitled "CCPA Exemptions"). As a result, in some cases, the applicable EquityMatch company may have no obligation under the CCPA to accept any CCPA requests, and in other cases, it may have no obligation to honor a particular CCPA request, because of the nature of the personal information that the EquityMatch company collects or maintains. Here are some examples of CCPA exemptions: 

• If your relationship and interactions with a EquityMatchcompany consist solely of personal financial services (e.g., maintaining one or more personal brokerage accounts), the personal information collected and processed about you is subject to the federal Gramm-Leach-Bliley Act ("GLBA") and therefore your CCPA request will not be honored by the EquityMatch company.


If you participate in a workplace retirement plan, or other employee benefit plan sponsored by or provided through your employer, that is serviced or administered by a EquityMatch company, CCPA requests should be directed to your employer.


Your Rights Under the CCPA 

The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA. As used below, a "consumer" means a resident of the State of California and a "covered business" means a business that is subject to the CCPA. 


Right to Know/Right to Access. A consumer has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the following: 

1. The categories of personal information it has collected about that consumer 

2. The categories of sources from which the personal information is collected 

3. The business or commercial purpose for collecting, selling or sharing (if applicable) personal information 

4. The categories of third parties to whom the covered business discloses personal information 

5. The specific pieces of personal information that the covered business has collected about that consumer 


These disclosures are not required to include any information about activity that occurred prior to January 1, 2022. Please also note that a covered business is not required to honor more than 2 of these requests from the same consumer during any 12-month period. 


Right to Delete. A consumer has the right to request that a covered business delete any personal information that the business has collected from the consumer, subject to certain exceptions.


 Right to Correct. A consumer has the right to request that a covered business correct inaccurate personal information that a business maintains about a consumer.


 Right to OPt-Out of Sale/Sharing If a covered business sells or shares personal information, a consumer has the right to opt-out of the sale or sharing of their personal information by the business. 

Right to Limit Use and Disclosure of Sensitive Personal Information. If a covered busines uses or discloses sensitive personal information for reasons other than those set forth in CCPA, a consumer has the right to limit the use or disclosure of sensitive personal information by the business. Non-Discrimination. A consumer has the right not to receive discriminatory treatment by the covered business for the exercise of privacy rights conferred by the CCPA.


Categories of personal information we may collect about you 

In general, if you are a customer of ours or you otherwise interact with us, we collect various types of personal information about you. The amount and types of personal information we collect will vary depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you. The categories of personal information that we may collect about you are: 

• Personal identifiers, such as your name, postal address, email address, on line identifier, internet protocol address, account name, or other similar identifiers • Information covered by California's records-destruction law (California Civil Code §1798.80), such as your signature, telephone number, and financial account information 

• Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

• Characteristics of protected classifications under California or federal law, for example, gender 

• Biometric information, such as when you use our voice-recognition service that we use for identity-verification and security purposes 

• Internet/Electronic network activity information, including, but not limited to, browsing history, search history, and other information regarding your interactions with our digital offerings or our advertisements 

• Geolocation data • Audio, electronic, visual, and similar data, such as call recordings • Professional or employment-related information, such as job title and business contact information • Education information • Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes • Sensitive personal information such as social security number, account log-in, password or credentials allowing access to your account(s) or to our digital offerings


The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, legal defense and legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services. 


Categories of sources from which personal information is collected

In addition to the sources described in the section above entitled "How and why we obtain and use personal information", depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we may obtain personal information from the following sources: • You or your representative, such as when using our products, services or digital offerings, when interacting with us or any of our service providers regarding our products, services or digital offerings or when otherwise communicating with us 

• Providers of publicly available information 

• Another person or other persons (typically people who know you) who provide referral information about you to us or who use the capabilities we offer on specific websites and applications to forward an article or other information to you

• Third parties that provide products and services to you through your relationship with us 

• Third parties that perform services for us or on our behalf Other third-party sources, including government sources, data brokers and social networks 

• Automatically, via technologies such as cookies and web beacons, when you interact with our digital offerings or electronic communications


Why we collect personal information 

Please see the section above entitled "How and why we obtain and use personal information" for a description of some of the business or commercial purposes for which we collect personal information, including sensitive personal information. In addition to those purposes described above, below are additional business or commercial purposes for which we collect personal information: • To provide you with information about products and services that may interest you 

• To maintain the accuracy and integrity of our records 

• For marketing and communication purposes 

• For reporting and analytical purposes • For personalizing your interactions and experiences with us 

• For training and quality-control measures 

• To verify your identity 

• To protect against malicious, fraudulent, or illegal activity 

• For business analysis, planning, and reporting 

• For customer education For effectiveness measurement


CCPA Exemptions 

Please note that certain types of personal information collected or maintained by a covered business are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases, no obligations, under the CCPA with regard to the following types of personal information: 

• Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) and implementing regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 [commencing with Section 4050] of the California Financial Code) 

• Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate pursuant to the Health Insurance Portability and Accountability Act of 1996.

In addition, some businesses are not subject to the CCPA, such as: 

• A business that does not do business in the State of California 

• A business that is not organized or operated for the profit of financial benefit of its shareholders or other owners

 • A business that does not determine the purposes and means of the processing of consumers' personal information 

• A business that has annual gross revenue of $25,000,000 or less


CCPA may refuse to honor a CCPA request to delete a consumer's personal information and is allowed to continue to maintain the personal information. Some examples include situations where retention of the personal information is reasonably necessary to: 

• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer or reasonably anticipated within the context of the covered business's ongoing business relationship with the consumer, or otherwise perform a contract between the EquityMatch company and the consumer 

• Help to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for those purposes 

• Debugging to identify and repair errors that impair existing intended functionality • Exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided by law 

• To enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer's relationship with the business and compatible with the context in which the consumer provided the information 

• Comply with a legal obligation


Please note that the description of the CCPA set forth in this privacy policy is a summary of only certain aspects of the CCPA and is not and should not be considered a complete description of the CCPA. In addition to what is described above, the CCPA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer's request to delete the consumer's personal information.


Submitting a CCPA Request If you wish to submit a CCPA request to any of the EquityMatchcompanies listed in this privacy policy, you may initiate your request through one of the options provided on our California Privacy Rights Request Page. Before submitting your request, please ensure you have reviewed all the CCPA exemptions, including those described above under the section above entitled "CCPA Exemptions". 


You should generally expect to receive a response within 45 days of the date we receive your request. However, in some instances, we may require an additional 45 days to process your request in which case we will notify you and explain why the extension is necessary. 

We will need to verify your identity before we can process your request. Through the request process, we will make you aware of any information that you will need to provide to us to process your request. You may have to confirm that you are a California resident and verify your identity or the identities of those authorized to submit requests on your behalf. Additionally, the information you provide will be used to help verify your identity. 


To understand how you can designate an authorized agent with the ability to make a request under the CCPA on your behalf, please refer to our California Privacy Rights Request Page. EquityMatch companies covered by this privacy policy received 12 CCPA requests for disclosure of personal information {request to know) and 18 CCPA requests for deletion of personal information {request to delete). EquityMatch companies responded to each of these requests in an average of 7.5 days.


EquityMatchFunds Privacy Policy 

Protecting your personal information is an important priority for the EquityMatch Funds. The Funds' privacy policy is designed to support this objective. The Funds collect non-public personal information concerning you in the following ways: 

• Information provided by you or your representative on applications or other forms furnished to the Funds or through other interactions that you or your representative have with the Funds 

• Information arising from your investments in or accounts with the Funds 

• Information the Funds receive from a consumer reporting agency 

The Funds employ physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you. 

The Funds do not disclose any non-public personal information about you, except as permitted or required by law. For example, the Funds have entered into a number of arrangements with EquityMatchInvestments and its affiliates as well as unaffiliated third-party service providers to provide for investment management, distribution, transfer agent, administration, valuation and other services to the Funds and Fund Advisors. 

If you decide to close your account, the Funds will continue to adhere to the privacy policies and practices as described in this policy. 

Please read the EquityMatch Funds Privacy Policy in conjunction with the Privacy Policy for the EquityMatchInvestments companies of which you are also a customer. 


The EquityMatchFunds Privacy Policy is provided on behalf of the EquityMatchInvestments family of funds, including those advised by Strategic Advisers LLC, and EquityMatch Diversifying Solutions LLC.


Updates to this Privacy Policy 

This Privacy Policy was last updated on the date indicated at the top of this Policy. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website. 


How to contact us 

We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Officer support@equitymatchinc.com or please contact EquityMatch Client Services through the EquityMatch website at https://equitymatchinc.com/