Equity Trust Company – Online Privacy Policy

Last Updated: October 10, 2025

This Online Privacy Policy (“Privacy Policy“) describes how Equity Trust Company and its affiliates (“Equity Trust,” “us,” “our,” or “we“) collect, use, disclose, and otherwise process Personal Information obtained through our websites, mobile applications (“Apps“), and online features that link to this Privacy Policy, including www.trustetc.com, www.myequity.com, and www.etcbrokerage.com (collectively the “Sites“).

For purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, or could reasonably be linked with an individual. Personal Information does not include publicly available, deidentified, or aggregated information.

For our existing and potential clients that use or apply for our services for personal, family, or household purposes, please see our Right to Financial Privacy Notice.

Personal Information Collection

We may obtain the following categories of Personal Information directly from you; through forms completed by you; when you subscribe to a newsletter; automatically when you use our Sites, including through Cookies, from your device, and from vendors; and from our partners, other vendors, and third parties. The Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

We may obtain the following types of Personal Information about you:

Contact information and other identifiers, such as name, postal address, unique personal identifier, online identifier, IP address, and email address. We may also collect Personal Information that is considered “sensitive” under certain laws, such as social security, driver’s license, state identification card, or passport number.
Characteristics of protected classifications, such as age, date of birth, gender, or marital status.
Commercial information, such as information about purchasing or consuming histories or tendencies.
Account and financial information, such as your account number; transaction history; assets; card number (e.g., debit or credit card number); username, password, and other similar credentials; income; investment preferences; and information about your financial standing, such as credit score and credit history. We may also collect Personal Information that is considered “sensitive” under certain laws, such as account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
Internet or other electronic network activity information, such as internet or other similar activity; browsing history; search history; browser type and language; operating system; Site access time; duration of visit; referring website address; webpages viewed immediately before and after our Site; and other information about your interaction with our Site.
Geolocation data, such as location inferred from your IP Address.
Professional or employment information, such as your title and affiliated company.
Content of communications, such as when you interact with us using a Site contact form.

We may combine your Personal Information with data we obtain from our Sites, our portal, our services, other users, and other parties. Your Personal Information may be converted into deidentified, anonymized, or aggregated data, as permitted by law.

Personal Information Use

We may use or otherwise process the Personal Information described above for the following purposes:

Business operations, such as providing services for ourselves, our customers or others, including maintaining and servicing accounts; managing applications and registrations; providing customer service; processing or fulfilling orders, transactions, and payments; verifying customer information; improving our services; responding to requests; managing our relationships with our customers, partners, service providers, and vendors; and fulfilling purposes that we describe at the time we collect Personal Information.
Site operations and improvement, such as maintaining, operating, optimizing, and providing access to our Sites; identifying Site visitors; monitoring and analyzing Site usage and trends; requesting ratings and reviews; evaluating how our Sites perform; repairing or improving the quality of our Sites; tracking and responding to quality and security issues; debugging our Sites to identify and repair errors that impair existing or intended functionality; developing new or enhanced products and service offerings; and ensuring our Sites operate effectively.
Communications, such as responding to questions or feedback; confirming preferences; providing information about our services; contacting you regarding products, services, and transactions; and understanding how you interact with our correspondence.
Advertising and marketing, such as sending marketing and promotional materials relating to our products, offerings, and promotions; serving advertisements; measuring the use of our services and effectiveness of our advertising and marketing; developing insights to improve our Sites; and providing our users with enhanced features and functionalities.
Security and integrity, such as protecting our Sites from cyber risks; authenticating Site users; enforcing our policies and terms; protecting our rights; fulfilling our legal obligations; preventing, identifying, investigating, and responding to fraud, illegal or malicious activities, and other activity that violates or may violate applicable laws, regulations, legal process, or our policies; and generally safeguarding our Sites.
Legal and compliance, such as managing risks, investigations, reporting, and other compliance activities; responding to court orders or other government and law enforcement mandates or requests; identifying or managing legal actions related to our or others’ rights or property; supporting actual or threatened claims, defenses, or declarations in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel; and enforcing compliance with applicable laws, regulations, or legal processes as well as industry standards and our policies.
Corporate restructuring, such as evaluating or executing a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, as part of regular business operations or pursuant to a bankruptcy, liquidation, or similar proceeding.

Personal Information Disclosure

We may disclose Personal Information obtained about Site visitors to:

Corporate Affiliates, including our affiliates, subsidiaries, and other related entities that may process your Personal Information as described in this Privacy Policy.
Vendors, service providers, and contractors that help us to administer our Sites, support Site activities, manage customer accounts, deliver services and communications, administer loans and other financial products, provide technical support, process payments, and otherwise help us operate our business. We may disclose Personal Information to Cookie providers, as described in the “Cookies and Other Online Tracking Technologies” section.
Ad Tech providers, including to provide personalized advertising, perform analytics, and as otherwise described below in the Cookies and Tracking Technologies section.
Parties to corporate transactions, such as prospective or actual purchasers, investors, or successor entities, in connection with a contemplated or an actual reorganization of our business, or in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets. This may include processing for the purpose of permitting the due diligence required to determine whether to proceed with a transaction.
Law enforcement agencies, courts, regulatory agencies, other government entities, professional advisors, affected parties, and other external parties in response to subpoenas, warrants, or court orders; for law enforcement or public safety purposes; in connection with any legal process; to investigate, prevent, or take action regarding possible illegal activities, fraud, safety of person or property, or a violation of our policies; to comply with laws, regulations, or other legal obligations; to protect and defend our rights and property or the rights and property of other parties; or to enforce our Terms of Use, this Privacy Policy, or agreements with third parties.

We may disclose your Personal Information to additional parties where we have provided a separate notice to you and/or asked for your consent, as applicable.

Cookies and Other Online Tracking Technologies

We and our vendors use cookies, pixels, and other online tracking technologies (collectively “Cookies“) to:

Collect and analyze information about your interactions with our Sites, such as by collecting information about which pages on our Sites you viewed or links you clicked and how you interacted with our content during your visit or over multiple visits;
Store information to improve our Sites functionality;
Help you access and navigate our Sites more efficiently;
Recognize your login information and preferences, so that you do not need to enter the information each time you visit our Sites; and
Deliver and customize advertisements and track campaign efficacy.

We and our vendors may collect Personal Information about your online activities over time and across different devices and websites when you visit our Sites, and link information collected by Cookies to other information collected about you.

In certain instances, we may contract with service providers to help us analyze activity on our Site through session replay technologies to help us understand and analyze how visitors use our Site, and to improve our services. These technologies may collect certain information about your usage, including IP address, screen size, device type, browser information, geographic location, and preferred language.

We may engage web analytics service providers, such as Google Analytics, to help us understand and analyze how visitors interact with our Sites. We use such data to administer and improve the quality of our Sites and serve ads on our behalf across the internet. We may also implement Google Analytics Advertising Features such as interest-based advertising, dynamic remarketing, and audience targeting.

Certain vendors we work with offer information about their privacy practices and tools you can use to limit or opt out of their Cookies, such as:

Google: For more information on how Google Analytics and other Google products use data, visit policies.google.com/technologies/partner-sites. To opt out of Google Analytics Cookies, visit tools.google.com/dlpage/gaoptout. To adjust your Google advertising settings, visit myadcenter.google.com.
Facebook: To change your privacy and advertising settings with Facebook, log in to your Facebook account and navigate to the Privacy Center at www.facebook.com/privacy/center or review your Ad Preferences at www.facebook.com/adpreferences.
LinkedIn: To change your privacy settings with LinkedIn, log in to your LinkedIn account and navigate to Account Settings and Privacy at www.linkedin.com/mypreferences/d/categories/privacy or review your Advertising Data at www.linkedin.com/mypreferences/d/categories/ads.
Microsoft: For information on how Microsoft collects or receives Personal Information through Cookies, visit the Microsoft Privacy Statements at www.microsoft.com/en-us/privacy/privacystatement.

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Sites are not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit allaboutdnt.com.

You may set your browser to notify you of or decline the receipt of Cookies; however, certain features of our Sites may not function properly or be available if your browser is configured to disable Cookies.

Some vendors may participate in the Digital Advertising Alliance (“DAA“”) or the Network Advertising Initiative (“NAI“”) opt-out programs. For more information about opting out or to use the DAA opt-out tool visit youradchoices.com/control. For more information about opting out or to use the NAI opt-out tool, visit optout.networkadvertising.org/.

We are not responsible for the effectiveness or accuracy of other parties’ notices or opt-out mechanisms.

Email Marketing

We may use your Personal Information to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving these types of communications from us by following the unsubscribe link or instructions provided in any email we send.

Interactive Features and Integrations

We may engage vendors to provide certain interactive features on the Sites. Your use of these interactive features is voluntary, and we may retain the information that you submit through the features. For example, we may offer an interactive chat feature on our Sites to answer questions and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.

Certain functionalities on our Sites permit interactions that you initiate between our Sites and external services, such as social networks (“Social Features“”). For example, Social Features enable you to “like” or “share” our content and pull or push information to or from our Sites. If you use Social Features, information you post or provide access to may be publicly displayed by the third-party service you use. Additionally, both Equity Trust and the third party may have access to certain information about you and your use of our Sites and the third-party service.

We may offer third-party integrations on our Sites. If you choose to connect a third-party account to our system, you should refer to that party’s privacy policy for information on how your Personal Information is processed and safeguarded.

We have implemented Google reCAPTCHA to protect our websites from fraud and abuse. Your use of reCAPTCHA is subject to Google’s Privacy Policy, available at policies.google.com/privacy, and Terms of Use, available at policies.google.com/terms.

Mobile Devices and Applications

We may disclose your Personal Information to our corporate affiliates, vendors, service providers, contractors, providers and other parties, as further described in the Personal Information Disclosure section above. To the extent we provide these parties access to your Personal Information obtained through our Apps, we require that they provide the same level of Personal Information protection as required by this Privacy Policy.

We will retain your Personal Information processed through our Apps for only as long as we reasonably consider it necessary for achieving the purposes set out in this Privacy Policy, or for as long as we are legally required or permitted to retain it. If you no longer wish to provide your Personal Information through our App, you may uninstall our App from your device. Note that deleting the App will not delete your user account or any information we previously collected via the App, nor does it affect our Personal Information collection through our other Sites.

Links to Other Websites

Our Sites may contain links to other websites or online services that offer goods, services, or information. Some of these websites may appear as windows-within-windows on our Sites. When you click on one of these links, you will be leaving our Site and will no longer be subject to this Privacy Policy. We are not responsible or liable for the information collection practices of the other websites that you visit and urge you to review their privacy policies and other terms to learn more about their data practices. The inclusion of a link to another website or online service does not imply our endorsement.

Safeguards

We implement reasonable technical, organizational, and administrative measures to safeguard Personal Information against unauthorized or unlawful processing and against accidental loss, destruction, or damage. However, because transmission via the internet is not completely secure, we cannot guarantee the security of any information we may have collected from or about you through our Sites.

Children’s Privacy

Our Sites are not intended for, nor targeted to, children under the age of 13, and we do not knowingly collect or retain any Personal Information from children under 13. If we become aware that we have received Personal Information from a person under the age of 13, we will delete the information in accordance with applicable law.

California Privacy Notice

The following California Privacy Notice applies to Personal Information obtained about California residents (“Consumers“) through this Site and in other contexts, including offline, pursuant to the California Consumer Privacy Act, as amended (“CCPA“).

Unless otherwise noted, the disclosures in this California Privacy Notice apply to our current practices, as well as our practices in the twelve (12) months preceding the Effective Date.

Consumer Personal Information Collection, Use, and Disclosure

We may obtain the Personal Information listed in the “Personal Information Collection” section above from our Site and other sources, such as when you contact us. In addition, we may collect the following categories of Personal Information about Consumers:

Personal Information described in Cal. Civ. Civ. Code § 1798.80(e),such as name; signature; address; telephone number; education and employment information; and bank account, credit or debit card number, and other financial information; and any similar information.
Audio, Electronic, Visual, or Similar information, such as voicemails, photos, videos, and audio recordings when you call a recorded line.
Inferences drawn from any other category of Personal Information to create a profile reflecting Consumer preferences, characteristics, behavior, abilities, attitudes, intelligence, aptitudes, or other similar predispositions.

We use and disclose these categories of Personal Information as set out in the “Personal Information Use” and “Personal Information Disclosure” sections above.

Sale or Sharing of Personal Information

Under the CCPA, a sale of Personal Information can refer to disclosures of Personal Information to third parties who may use the information for their own purposes, such as Cookie vendors. Similarly, under the CCPA, sharing Personal Information refers to disclosing Personal Information to third parties for cross-context behavioral advertising. In this context we sell and share the following categories of Personal Information through some of our Sites: contact information and other identifiers, Personal Information described in Cal. Civ. Civ. Code § 1798.80(e), internet or other electronic network activity, commercial information, geolocation data, and inferences. We have sold and shared Personal Information to our Cookie vendors and adtech providers for cross-context behavioral advertising and other marketing and advertising services that we utilize on our Sites. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Consumer Personal Information Retention

We retain the Consumer Personal Information described in this Privacy Policy for as long as is necessary to fulfill the purposes described in this Privacy Policy, or as otherwise authorized or permitted by law. Personal Information is retained for as long as the retention of Personal Information is reasonably necessary to:

Manage our operations, manage your relationship with us, or satisfy another purpose for which we collected the information;
Carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected; or
Protect or defend our rights or property and/or protect our ability to exercise those rights.

Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

California Privacy Rights

Consumers have the following rights regarding your Personal Information:

Rights to Know and Access: The right to know and access the Personal Information we have collected about you, including:

The categories of Personal Information that we process about you;
The categories of sources from which the Personal Information is collected;
Our business or commercial purposes for collecting, selling, or sharing Personal Information;
The categories of third parties to whom we disclose Personal Information; and
The specific pieces of Personal Information that we have collected about you.

Right to Delete: The right to request that we delete Personal Information that we have collected from you, subject to certain exceptions.
Right to Correct: The right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Opt Out of Sales and Sharing of Personal Information: The right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. Our Sites that sell and/or share personal information will offer a “Do Not Sell or Share My Personal Information” link in the Site footer. To opt out, click this link and configure your selling and sharing preferences. If a Site does not offer such a link, we have not determined that the Site sells or shares Personal Information.
Right to Limit Use and Disclosure of Sensitive Personal Information: The right to limit the use and disclosure of your sensitive Personal Information if it is used or disclosed in certain ways. We do not use or disclose your sensitive Personal Information for purposes for which the right to limit use and disclosure applies under the CCPA.

We will not discriminate against you for exercising your privacy rights.

Submitting a Request Related to California Privacy Rights

If you wish to exercise your rights, you may email us at [email protected].

Note that to process your request, we may require you to verify your identity by logging into your account and/or providing 2-3 pieces of information that we will match against our records.

You may use an authorized agent to request access to, correction of, or deletion of your Personal Information. We will require you or your authorized agent to provide us with information to verify your identity. We may also require you to either verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request

Visitors from Outside the United States

By using our Sites, you acknowledge your Personal Information may be transferred to and processed in jurisdictions outside your own, including the United States, as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your Personal Information transferred to the United States or other countries may be different from the laws in your country of residence.

Privacy Policy Updates

We may add to, delete, or change the terms of this Privacy Policy from time to time. Your continued use of our website or any website service following our notification of material changes will constitute your agreement to the revised policy. Changes to this Privacy Policy will be effective as of the Last Updated date at the top of this page, unless otherwise expressly indicated.

Contact Us

If you have any questions regarding this Privacy Policy or our privacy practices, you may email us at [email protected].