Vestorly, Inc. (“ Vestorly ”, “ we ”, “ us ”, “ our ”) provides content (“ Content ”) that our customers (“ Clients ”) make available to their clients and prospective clients (“ End Users ”). This Privacy Policy applies solely to information that we collect about End Users accessing this Content.

This Privacy Policy explains what information may be collected when an End User accesses Content, how such information may be used and/or shared with others, how we safeguard it, and how you may access and control its use.


Information You Provide To Us

When an End User accesses Content, we or our service providers may collect Personal Information (information that could reasonably be used to contact or to identify the End User personally) such as name, e-mail address, telephone number, mobile phone number, mailing address, or investor suitability information that either the End User provides us or allows us to obtain from our Clients or otherwise.

Information Collected Automatically

Usage Information. Vestorly, as well as our Clients, and other third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Content is accessed and used (“ Usage Information ”). Usage Information may include, in part, browser type, operating system, the page served, the time, and the preceding page views. These statistical data provides us with information about the use of the Content, such as how many visitors visit a specific page of the Content, how long they stay on that page, and which hyperlinks, if any, they “click” on. This information helps us keep our Content fresh and interesting to End Users and to tailor Content to an End User’s interests.

Device Identifiers. Vestorly may also automatically collect your IP address or other unique identifier (“ Device Identifier ”) for the computer, mobile device, technology or other device (collectively, “ Device ”) that an End User uses to access Content. A Device Identifier is a number that is automatically assigned to a Device when it accesses a web site or its servers, and our computers identify the Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Content, help diagnose problems with our servers, analyze trends, track End Users’ web page movements, help identify, and gather broad demographic or firmographic information for aggregate use.

Cookies; Pixel Tags. The technologies that we use to collect Usage Information, including Device Identifiers, may include but are not limited to: cookies (data files placed on a Device when it is used to visit the Site), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). Cookies may also be used to associate and End User with social networking sites like Facebook and Twitter and, if the End User so chooses, enable interaction between your activities accessing Content and your activities on such social networking sites. We, or our vendors, may place cookies or similar files on a Device for security purposes, to facilitate site navigation and to personalize an End User’s experience while accessing Content (such as allowing us to select which Content, ads or offers are most likely to appeal to an End User, based on an End User’ interests, preferences, location, or demographic or firmographic information). A pixel tag may tell a browser to get content from another server.

Similarly, we may use Google Analytics to help us track and analyze usage of our Content, using cookies, pixels and other tracking technologies.

A browser’s help menu or other browser instructions explains how to reduce the number of cookies received from us, or to delete cookies that have already been installed. An End User that disables or opts out of receiving cookies should be aware that some features and services that we provide may not work properly because we may not be able to recognize and associate an End User with the End User’s account(s). Some browsers have a “Do Not Track” feature that can tell websites that an End User does not want to have online activities tracked. These features are not yet uniform, so our systems are not configured to recognize Do Not Track headers or signals from some or all browsers.

End Users can also learn more about cookies by visiting which includes additional useful information on cookies and how to block cookies using different types of browser.


Any information an End User submits to us when accessing Content or allows us to obtain will be used for a variety of business purposes, including for example, to: respond to questions and requests; provide access to certain areas and features of Content; verify an End User’s identity; communicate with End Users about how they access and use Content and, in our discretion, changes to any Vestorly policy; tailor Content, advertisements, and offers we serve to End Users; market research, web server analytics and operations; improve our web servers and for other internal purposes; and for purposes disclosed at the time that an End User provides or otherwise allows us to obtain Personal Information.


Except as provided in this Privacy Policy, we will not provide any of Personal Information to any third parties without an End User’s consent. We may share non-Personal Information, such as aggregate user statistics, demographic or firmographic information, and Usage Information with third parties. We may also share Usage Information, or Personal Information as disclosed at the time that an End User provides or allows us to obtain it, as set forth in this Privacy Policy and in the following circumstances:

Clients. We may share an End User’s Personal Information and Usage Information with a Client that has provided access to our Content to that End User to solicit the End User’s engagement of the Client for its services and to enable Clients to improve their services and tailor their services for particular End Users.

Other Third Parties. To carry out an End User’s requests, to make Content and various features, services and materials available, and to respond to End User inquiries, we may share Personal Information with third parties that perform functions on our behalf, such as companies or individuals that: host or operate our web servers; analyze data; or provide customer service.

Agreement To Have Information Shared. If an End User agrees to our sharing Personal Information or Usage Information, the information will be disclosed to the Client or other third party and will be subject to the privacy policy and business practices of that third party.

Business Transfers. Personal Information may also be used by us or shared with our subsidiaries or affiliates, for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, Personal Information, Usage Information, and any other information that we have collected may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Disclosure. Vestorly may transfer and disclose information, including Personal Information, Usage Information and Device Identifier, (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, End Users, or the public.


An End User may direct us not to share Usage Information or Personal Information with third parties, not to use Usage Information or Personal Information to provide you with information or offers, not to send you newsletters, e-mails or other communications, or verify, correct, or update Personal Information by sending us an e-mail or contacting us by mail at the address set forth in paragraph 10 or following the removal instructions in the communication that you receive. An opt-out request will be processed within 30 days of the date on which we receive it.

In accordance with our routine record keeping, we may delete certain records that contain Personal Information. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, it is not always possible to completely remove or delete all information from our databases without some residual data because of backups and other reasons.


We do not knowingly collect Personal Information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent.


We use certain reasonable security measures to help protect Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any Personal Information transmitted to us; an End User’s accessing Content or providing us with Personal Information is at the End User’s own risk.


Content may contain links to other sites that we do not own or operate, including links from Clients, service providers, advertisers, sponsors, or others that may use our logo(s) as part of a co-branding agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other web sites may send their own cookies to your Device, independently collect data, or solicit Personal Information and may or may not have their own published privacy policies.


We are governed by and operate in and in accordance with the laws of the United States. We make no representation regarding compliance with the laws of any other country. End Users located in the European Union, Canada or elsewhere outside of the United States should be aware that information we collect may be transferred to and processed in the United States. By using our Content, or providing us with any information, each End User (a) acknowledges that we are subject to the laws of the United States, (b) consents to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where the End User resides or is a citizen, and (c) waives any claims that may arise under those laws.


Please note that we may change this Privacy Policy at any time without prior notice, and any changes will be effective immediately upon the posting of the revised Privacy Policy on our website. However, Vestorly will use Personal Information in a manner consistent with the Privacy Policy in effect at the time the information was submitted, unless the End User consents to the new or revised policy.


If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Attn: Vestorly, Inc.
Address: 335 Madison Avenue, 8th Floor, New York NY 10017
Re: Vestorly Privacy Policy