Privacy Policy

About this notice and its scope

Independent Franchise Partners, LLP (“Franchise Partners,” “we” or “us”) is committed to protecting and respecting your privacy. This notice (together with any other documents referred to in it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us as a data controller.

Please read the following carefully to understand our practices regarding your personal information and how we will treat it.

If you are an investor located in the United States, you may find our Notice of Privacy Practices and other relevant privacy notices in the US Customer Privacy Policy Notice at the end of this privacy notice.

If you are located in certain jurisdictions, additional terms may apply to our processing of your personal information which are set out at the end of this privacy notice. Applicable laws may give you additional rights that are not described in this privacy notice.

Any other privacy notices supplement this privacy notice and are not intended to override it.

For the purpose of the UK General Data Protection Regulation, (and any other applicable data protection legislation) (the “UK GDPR”), the data controller under this notice is Independent Franchise Partners, LLP of Level 1, 10 Portman Square, London, W1H 6AZ, United Kingdom.

Information Collection Practices Overview

It is our policy to only obtain the Personal Information that is necessary to provide our products and services to you and to limit the access to customer Personal Information to only those individuals who need it to serve our Customers’ and Website Users’ needs.

Iinformation we may collect from you

Information That We Collect From You When You Visit Our Website

We may collect and process the following data about you when you visit our Website at https://www.franchisepartners.com/:

Information you give us.

When you fill out a contact form on our Website, we will collect certain Personal Information about you such as your name, address, e-mail address, employer information and telephone number. We may also collect Sensitive Personal Information, such as your gender and possibly financial information if you include the same within the message.

Information Automatically Collected on Our Website

We also may use various technologies and methods to collect information directly from you or from your computer or device and about your activities on our Website.

Information collected automatically: We may automatically collect information from you when you visit our Website. This information may include technical information, including the IP address used to connect your computer or device to the internet, information relating to your browser and operating system and your activity on the Website.

As described in our Cookie Policy, we use Google Analytics to collect information about your use of our Website as well. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at https://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please see: https://policies.google.com/technologies/partner-sites.

We may also collect information from you automatically through any site or web application that we may develop and run on a third party social network such as LinkedIn.

Cookies and other tracking technologies: When you visit our Website, we may assign your device one or more cookies to facilitate access to our site and to personalize your online experience. You can learn more about our use of cookies and other tracking technologies (including web beacons, pixels, and other similar technologies) on our Website and in e-mail messages or newsletters and what they are here: Cookie Policy.

Information That We Collect From you if you are one of our Customers

Information you give us.

We may collect and process your personal information if you are one of our Customers (for example, through a fund), or if you are an individual who is connected with an investor or a service provider to an investor (for example, a director, officer, employee, representative, shareholder, investor, client, beneficial owner or agent):

in connection with an investment (or a prospective investment); or
as a result of any associated interactions with us (including the initial or subsequent application for shares, and including the recording of electronic communications or phone calls where applicable); or
by virtue of you otherwise providing us with personal information, including as a consequence of entering into an Investment Management Agreement with us.

We may collect or you may give us information (including personal information) about you when meeting with us in person or by corresponding with us by phone, e-mail or otherwise. This information may include:

Your contact details: your name, title, address, e-mail address, phone number, and where relevant, your job title, business contact details and details of any organisations that you represent;
Your transaction and investment details: investment holdings, bank details, tax forms, details relating to your investment activity;
Your identification details: copies of identification documents such as your driving licence and/or passport; or
Correspondence between us: including any personal information contained in free text boxes that you fill in, e.g. through any enquiries or comments that you submit via the Website.

Information we receive from other sources.

We may also collect information about individuals connected with our service providers (for example directors, officers, employees, representatives, or agents) as a consequence of us engaging that service provider. We will treat such personal information in accordance with this notice.

We also work closely with other third parties (including, for example, investment consultants, business partners, sub-contractors in technical services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

We may collect limited data about your criminal convictions and offences or political opinions to the extent necessary for checks for Politically Exposed Persons (PEP) and/or sanctions if you are connected with an investor (for example, as a director or shareholder). We do not collect any other Special Categories of personal information (or Sensitive Personal Information) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any other information about criminal convictions and offences.

Uses made of the information

We will only use your personal information when the law allows us to. Such “legal grounds” may include using your data:

in order to perform a contract with you or to perform our obligations under a contract with you,
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, with some examples given below, or
where we need to comply with a legal obligation.

We may process your personal information for more than one of these legal grounds depending on the specific purpose for which we are using your personal information.

Where we need to collect and use your personal information for contract performance or because the law requires us to collect it, we might not be able to enter a contract with you or perform it or provide products or services to you if you don’t provide us with this information. In this case, we might have to cancel the contract or service you have with us but we will notify you if this is the case at the time.

Why we collect your information

Where you are an individual connected with an investor (including a prospective investor), an individual connected to our service provider, or (in respect only of certain points below which refer to the Website use) a visitor to our Website, we use information held about you for the following purposes:

Purpose	Categories of personal information	Lawful basis (legal ground)
To facilitate the opening of an investment account with us or with the funds whose portfolios we manage, the management and administration of underlying investments and any related account on an on-going basis (the “Services”). If you are a Customer in the US, please see our US Customer Privacy Policy Notice at the end of this privacy notice.	Your contact details, your transaction and investment details	Contract performance
To provide you with other information, products and other services that you request from us from time to time	Your contact details, correspondence between us	Legitimate interests (providing you with information about our services)
Contract management when you are not an investor but are connected to an investor or service provider	Your contact details, correspondence between us	Legitimate interests (managing contracts with our customers and suppliers)
To carry out anti-money laundering (“AML”) checks and related actions including in relation to: preventing fraud, money laundering, terrorist financing, bribery, corruption or tax evasion; and preventing the provision of financial and other services to persons who may be subject to economic or trade sanctions, in accordance with our anti-money laundering procedures; any subsequent screening where necessary.	Your contact details, your identification details, your transaction and investment details	Legal obligation to the extent that our processing relates to a legal obligation to comply with our legal and regulatory obligations to undertake AML/KYC checks Otherwise, legitimate interests (to prevent fraud, money laundering and other misconduct and comply with any regulatory obligations). Where we are undertaking checks for Politically Exposed Persons (PEP) and/or sanctions, this may require processing of personal information relating to criminal offences and convictions, sanctions or political views (as applicable). For this we rely on necessity for reasons of substantial public interest (anti-fraud measures and/or compliance with applicable laws, particularly the Sanctions and Anti-Money Laundering Act 2018)
To report tax related information to tax authorities	Your contact details, your transaction and investment details	Legal obligation
To update and maintain records and fee calculations and for internal records management	Your contact details, your transaction and investment details	Contract performance to the extent that this relates to calculations in respect of the contract between us. Otherwise, legitimate interests (to operate our business efficiently)
To administer our Website, including through: allowing you to participate in interactive features of the Website, when you choose to do so; administering the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and keeping the Website and related IT architecture safe and secure, including for the investigation of any alleged security breaches	Your contact details, correspondence between us, website and communication usage, log in details	Legitimate interests (to deliver our services through the Website and ensure safety and security of our systems)
Improvement and development of our business which includes using your data to: monitor and record calls for quality control, business and statistical analysis, training or to improve service delivery; improve our products and services and the Website and ensure that content from the Website is presented in the most effective manner for you and for your device.	Your contact details, correspondence between us, website and communication usage, log in details	Legitimate interests (to improve our business)
To identify you when you contact us and we correspond with you	Your contact details, correspondence between us	Where you are an investor or potential investor, contract performance to the extent that your correspondence relates to the contract between us. Otherwise, legitimate interests (to communicate with our customers and service providers)
To obtain business support from our service providers, auditors, technology providers and other service providers	Any personal information that we hold for you	Legitimate interests (to obtain professional support)
To comply with our legal obligations	Any personal information that we hold for you	Legal obligation
To communicate with regulatory authorities	Any personal information that we hold for you	Legal obligation where compliance with the requests of the regulatory authority is compulsory. Otherwise, legitimate interests (to comply with our regulatory obligations)
To enforce our rights and/or to defend ourselves	Any personal information that we hold for you	Legitimate interests (to bring and defend legal claims)
To restructure our business	Any personal information that we hold for you	Legitimate interests (restructure or sale of our business)

Accordingly, you understand that we may use your personal information for these purposes, provided that we act in a fair, transparent and accountable manner and take appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such use, as discussed below.

Given the specific purposes for which we envisage using your personal information, we do not anticipate being required to obtain your consent to do so. Should we wish to use your personal information for other specific purposes that require your consent, we will contact you to request this.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your information

We may share your personal information with third parties as set out in this notice or where otherwise required to do so by law.

We may disclose your personal information for the purposes set out below:

to third parties including our suppliers, sub-contractors, and technical services providers, as required for our everyday business purposes, including to provide you with the information, products or services you request.
to our professional advisors in order to obtain advice in respect of our business;
to competent authorities (including tax authorities), courts and bodies as required by law or where requested; or to protect the rights, property, or safety of Independent Franchise Partners, LLP, its customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction;
to an authorised financial advisor or investment consultant or other third parties that you involve in the administration of your investments;
to credit reference agencies in order to carry out money laundering and identity checks and comply with legal obligations;
to purchasers or prospective purchasers of the whole or part of our business.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. Generally, we do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We do not Sell your Personal Information and Do not Share it with Third Parties for Cross-Contextual Advertising

Franchise Partners does not sell your Personal Information, and also does not share your Personal Information with third parties for purposes of cross-context behavioral advertising.

International transfers

The personal information that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by staff operating outside the UK who work for us or for one of our service providers (for example, in the US). Such staff may be engaged in, among other things, the provision of support services. Where your personal information is transferred outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information. For further details of the countries and territories for which the UK has issued adequacy regulations, see here. All EU/EEA countries have been approved in this manner by the UK.
We may use specific contracts approved for use in the UK which give personal information the same protection it has in the UK and require the recipient to protect it (for example, where transferring to countries outside the UK listed above). For further details, see the template text of these contracts on the UK data protection authority’s (UK ICO’s) website here.
We may be legally permitted to transfer your personal information outside the UK using other methods or relying on another legal exception.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.

Third-party sites

The Website may, from time to time, contain links to and from the websites of our business partners, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those staff members, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Unfortunately, however, there is no way to completely eliminate the risk of a data security incident. If we do suffer one that affects any of your Personal Information, we have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We also ask that you do your part to keep your account information safe and secure, by asking that Where you have set a password, you create a sufficiently complex password for your account and not share it with third parties, as outlined in our terms of use available at Website terms of service.

Your rights

It is within your rights under applicable law, in certain cases, to request:

a copy of your personal information that we process;
details about such personal information, including the purposes and potential recipients of this data;
to have such personal information rectified in case of any inaccuracies or deleted if we no longer have a lawful ground to use it;
to restrict or object to the processing of your personal information; and
a copy of your personal information in a standardised format so that it can be provided to another vendor.

Please note that the right for your data to be erased (the “right to be forgotten”) that applies in some contexts under the UK GDPR is not likely to be applicable to most, if not all, of the personal information you provide to us in relation to an investment, given the specific nature of the purposes for which we use that data, as described above.

Where you have provided (and we have relied upon) your consent to process your personal information, you may withdraw your consent at any time by contacting us at the address stated below and (where no other legal basis exists upon which we can process your data) we will apply your preferences going forward. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent.

In some circumstances, withdrawing your consent (for example, by opting out) or objecting to the processing of your personal information, or requesting its deletion, will mean that you cannot take advantage of certain Services or investment opportunities, and we may need to suspend or terminate your access to the Services or to the Website.

Where we require your personal information to comply with AML or other legal requirements, failure to provide this information means we may not be able to accept an investment.

If you wish to exercise any of your legal rights set out above, please contact privacy@franchisepartners.com or write to The General Counsel, Independent Franchise Partners LLP, Level 1, 10 Portman Square, London W1H 6AZ, UK.

As we must be able to identify the person making the request, we may require you to confirm your request by different means, by contacting us at the address stated above. Due to technological constraints and/or information security considerations, it may be inappropriate to use social media to supply information in response to any request by you for access to information, and so please provide an alternative delivery address for our response.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Retention of information

We will retain your personal information for as long as is necessary to fulfil the relevant purpose for which it was collected, including as required to perform the Services, to deal with subsequent enquiries or disputes, or longer where additional legal/regulatory obligations require us to do so.

When we no longer have a legal need, or you close or delete your account with us, or otherwise ask us to delete your account, we will do so securely in accordance with our document retention policy.

Third party applications and sites

Our Website may provide links to, or features from, other third party sites that we do not own or control. Although we choose our business partners carefully, when you visit these third-party sites and decide to share your Personal Information with them, you are assuming the risk of doing so. IFP is not responsible for nor assumes any liability for the privacy practices of websites operated by any third parties, including those that may be linked to our Website, and including the content of those sites. You should check the applicable privacy notice and/or policy of the third party website or application to understand how it collects and manages any information they collect from you.

IFP does not endorse or control any other websites or applications besides our Website, nor does the act of providing a link to a third party website or application constitute an endorsement, promotion or approval of such website or application.

Changes to our privacy notice

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

California residents legal notice

Categories of Personal Information that we collect:

Categories of Personal Information	Categories of Sources of This Information
Identifiers (i.e., a legal name, nickname, physical home address, internet protocol address, email address, phone number, an online identifier, etc.)	Information you provide directly to us or collected from our Website.
Internet Information (i.e., browsing history, WiFi use, and internet search history)	Information you provide directly to us or allow us to collect and use from your devices or from our data analytics providers (e.g. Google Analytics).
ID information (copies of identification documents such as your driving licence and/or passport)	Information you provide directly to us or is provided to us by a third-party investor.
Financial Information (i.e., Your investment information or other financial account information).	Information you provide directly to us or is provided to us by a third-party investor.
Other Sensitive Personal Information (i.e., your social security number)	Information you provide directly to us or is provided to us by a third-party investor.

Sale or Sharing of the Personal Information and Sensitive Personal Information of Persons Under the Age of 16 (or 18)

Our Website and services are not meant for, marketed to, or directed at, children under the age of 18 years of age. We do not sell or share the Personal Information of persons under 18 years of age.

Use and Disclosure of Sensitive Personal Information

We do not use or disclose Your Sensitive Personal Information for any other purpose other than to perform business services, including to provide our services to you.

Sale or sharing of Your Personal Information for Our Business Purposes

As noted above and in our Cookie Policy, we utilize Google Analytics and may utilize a third-party advertising company for purposes of mailed targeted advertising, which can both be considered a sale under California law. This would be the only way in which we “sell” your information.

We do need to share your Personal Information with third parties for our business purposes, as noted above.

The categories of third parties that we need to share your Personal Information with and the Categories of Personal Information that we share with those parties are:

Categories of Third Parties	Categories of Personal Information Shared with the Third Party
Advertising Companies	Identifiers, Geolocation Data, and Internet Information.
Data Service Providers	We do not share your Personal Information or Sensitive Personal Information directly with these providers, but they may receive records as part of providing services to us that may contain Identifiers, Geolocation Data, Internet Information, ID information, Financial Information, and Other Sensitive Personal Information.
Legal Representatives	Depending on the need, we may need to share your Identifiers, Geolocation Data, Internet Information, Financial Information, and Other Sensitive Personal Information.
IT Service Providers	Identifiers, Geolocation Data, and Internet Information.
Law Enforcement, Courts, or other related Legal third parties that are not our legal representatives	Depending on the need and related law, we may need to share your Identifiers, Geolocation Data, Internet Information, ID information, Financial Information, and Other Sensitive Personal Information.
Auditors	Depending on the need, we may need to share your Identifiers, Geolocation Data, Internet Information, Financial Information, and Other Sensitive Personal Information.
Accounting Representatives	Depending on the need, we may need to share your Identifiers, Financial Information, and Other Sensitive Personal Information.
Our Affiliated Brands and Companies	We may need to share your Identifiers, Geolocation Data, Internet Information, ID information, Financial Information, and Other Sensitive Personal Information.

Why We Collect This Information From You

We use this information from you to provide our services and offer our products to You and for our business purposes as outlined above.

Categories of Our Business Purposes That Are Used to Share your Personal Information:

As noted above, we share your Personal Information and Sensitive Personal Information as needed in order to provide our services and products to you and for our business purposes. Specifically, these categories of business purposes are:

Auditing – We may share this information with our third-party vendors, partners and service providers, and our own auditors related to an audit of our business.
Service Improvements – We may share this information with our third-party vendors, other partners, and service providers in order to improve our services and products, create new services and products, offer new products, and to ensure that our Website is working as intended (to identify bugs and errors, and repair them).
Service Partners – We may share this information our third-party vendors, other partners, and service providers in order to have them perform their services for us, pursuant to a written contract that includes the notified purposes permitted by the CCPA.
Security and Legal Issues – We may share this information with law enforcement or other individuals pursuant to a valid subpoena or other legal obligation, our third-party vendors, other partners, and service providers in order to detect, prevent, and investigate security incidents.

Your Rights Under the CCPA

You, or your authorized agent, can request the specific pieces of Personal Information we have collected about you by emailing privacy@franchisepartners.com. You can also request that we disclose how we have collected, used and shared your personal information over the past 12 months, including the categories of Personal Information we collected and our purposes for doing so. You may also request the categories of the sources of that information, the categories of the third parties with whom we have shared this information for a business purpose, and our business purpose for doing so.
You have the right to correct inaccurate Personal Information that we have collected or maintain about you. In fact, we ask that you do so as soon as you realize any Personal Information that we have collected is inaccurate as it could impact our provision of the Services.
You have the right to opt out of sale of your information.
You have a right to be notified when we collect information from you, and we cannot collect new categories of information from you without notifying you first.
You have the right to limit our sharing of your Personal Information.
You have the right to not be discriminated against for exercising these rights.
You have the right to ask us to delete your Personal Information.

How to Exercise Your Rights

If you would like to exercise any of the rights listed above with regards to your Personal Information, then please contact us, or have your registered agent contact us, at privacy@franchisepartners.com.

If you want to review and request changes to your Personal Information, you may also email or call us as noted below, and we will then provide you with detailed instructions on how to do so.

Nevada residents privacy rights

As noted above, we may share your Personal Information with our analytics provider. We otherwise do not sell, rent, or otherwise share your data to any third party in exchange for monetary or other valuable consideration under any circumstances unless you specifically consent to such disclosure. Pursuant to Section 603A of the Nevada Revised Statutes, residents of Nevada may, at any time, submit a request to an operator of a website in Nevada directing the operator not to make any sale of any Personal Information the operator has collected or will collect about the consumer. If you are a Nevada resident and want to opt-out of the sale of any personal information, please submit an email request to privacy@franchisepartners.com. In your request, please specify that you want to “Opt-Out of Sale of Personal Information in Nevada.” Please allow 60 days for a response.

Children’s personal information

Our Website and services are not made for, marketed to or directed at children under the age of 18. We do not sell the Personal Information of persons under 18. In the event that we learn that the Personal Information of a person under 18 years of age has been collected, we will delete it immediately from our system.

Do not track (“Dnt”) settings

DNT is a setting on some web browsers or mobile devices that can be turned on to instruct websites to disable tracking of your web browsing activities. DNT is not currently widely adopted and does not have clear standards or guidelines as to how websites are to interpret it. Additionally, its signals can affect the functioning of certain websites. As such, IFP does not generally respond to these signals.

We recognize the Global Privacy Control.

Third-party tracking on our website

Third parties may be using cookies or other technologies to collect your personal information as you navigate through the internet including from our Website. As described in our Cookie Policy, you may decline these third-party cookies by changing your browser settings.

To the extent these online tracking technologies, which include targeted advertising, are deemed to be a “sale” / “sharing” as defined under applicable U.S. laws, you can also opt-out of these online tracking technologies by contacting us at privacy@franchisepartners.com.

US customer privacy policy notice

Overview

This notice is meant to provide our valued customers with information about Independent Franchise Partners, LLP (“Franchise Partners,” “we,” “us,” and “our”) Privacy Practices, when it comes to the Nonpublic Personal Information that we need to collect from you when you invest money with us.

Title V of the Gramm‐Leach‐Bliley Act (“GLBA”) generally prohibits any financial institution, directly or through its affiliates, from sharing nonpublic personal information about you with a nonaffiliated third party unless the institution provides you with a notice of its privacy policies and practices, such as the type of information that it collects about you and the categories of persons or entities to whom it may be disclosed. In compliance with the GLBA, we are providing you with this document, which notifies you of the privacy policies and practices of IFP.

Definitions

“Customer” means a natural person who is utilizing our services for personal, family, or household purposes.

“Nonpublic Personal Information” means any personally identifiable financial information that IFP collects about its Customers in order to quote, perform and support the investment management. Nonpublic Personal Information does not include any information that is Publicly Available.

“Publicly Available” means information made available to the public via federal, state, or local government records (i.e., the filing of a mortgage on a property). Publicly Available also includes information that is contained in widely distributed media and made available to the general public on an unrestricted basis, even if there is a fee for access or a password protected access to the media (i.e., telephone books, newspapers, and websites),

Franchise Partners’ Information Collection Practices Overview

Franchise Partners offers a range of products and services, including investment management. To provide these services, we may collect and process both personal and non-personal information from our Customers. It is our policy to only obtain the Personal Information that is necessary to provide our services to you and to limit the access to customer Personal Information to only those individuals who need it to serve our Customers’ financial needs. We strive to provide the best service and thus, certain information may also be used to maintain and improve our customer service to you. In general, we only disclose a customer’s Personal Information to our affiliates and other professionals we work with or to our services providers (for example, IT service providers) when necessary to conduct business, or as required by law.

Information We Collect from You

We collect certain Nonpublic Personal Information about you in order to provide our services to you. We describe what information we collect and how we obtain it below. Unless it is specifically stated otherwise in an amended Privacy Policy Notice, no additional Nonpublic Personal Information will be collected about you.

Information Provided by You

When you fill out an application with us, we will collect certain Nonpublic Personal Information about you such as your name, address, e-mail address, and telephone number.

We may also need to collect your financial information, depending on the services being provided.

Information Provided by Your Employer or an investor you are connected with

There may be times when your Employer or an investor you are connected with (for example, if you are a shareholder or director of an investor or an individual investing through a fund) needs to share information with us directly in order to receive the benefit of our services and/or manage your account with us. In those situations we will collect your Nonpublic Personal Information from them in order to process your information to submit for that process.

Information Provided by other Third Parties

We may collect some Nonpublic Personal Information from our service providers who assist us with anti-money laundering and fraud prevention checks such as results of checks against the Politically Exposed Persons lists.

Who We Share Your Personal Information With

As noted above, we may need to share your Nonpublic Personal Information for different reasons. Based on those reasons, we may share your Nonpublic Personal Information with the following third parties, including:

Authorized service providers and affiliates: We may share your Nonpublic Personal Information with our authorized service providers that perform certain services on our behalf. These services may include relationship management software; brokers and agents; email marketing providers; customer service providers; and providers that perform business and operations analysis for us.

State financial regulators and government entities: Upon request or in connection with a legal reason, we may provide your Nonpublic Personal Information to financial regulators and other governmental entities for fraud investigations or other regulatory purposes.

Sale of Your Nonpublic Personal Information

We do not sell your Nonpublic Personal Information other than to the extent necessary for our use of Google Analytics. Additionally, we do not disclose any Nonpublic Personal Information about you with anyone for any purposes that is not specifically permitted by law.

How We Secure Your Nonpublic Personal Information

IFP maintains a comprehensive Information Security Program that employs commercially available physical and IT securitization tools, including but not limited to:

Commercially available and sufficient firewalls;
Segmented Data Storage;
Multi-factor authentication; and
Policies providing for least privileged access to data across our organization.

Unfortunately, however, there is no way to completely eliminate the risk of a data security incident. If we do suffer one that affects any of your Nonpublic Personal Information, we will report the same to you as per applicable data breach notification laws.

Updated 15 April 2026