Privacy Notice
General Information
This privacy notice (“Privacy Notice”) describes the types of information that are identifiable to a particular person (“Personal Information”) that Kurv Investment Management LLC (“Kurv”, “we”, “us”, and “our”) collects from you or about you when you use or access our website (https://www.kurvinvest.com) (the “Site”) and in the course of providing its customers and shareholders with products and services, as well as our practices for using, sharing, and protecting that information. We urge you to read this Privacy Notice to ensure you are fully informed.
Kurv reserves the right to change this Privacy Notice at any time. If we decide to change the Privacy Notice, we will post the changes on the Site so that you are aware of the changed Privacy Notice. We encourage you to check the Site for policy revisions. To stay current on our practices, please update your email address with us if it changes. We will send you an email notification discussing any material revisions to the Privacy Notice if we have your current email address.
This Privacy Notice does not apply to any activity on third-party websites and mobile applications that may link to the Site. Our Site may contain links to other websites or platforms. These websites operate independently from us, and their privacy practices are subject to their own privacy policy or policies, which we strongly encourage you to review to understand their procedures for collecting, using and disclosing Personal Information. We are not responsible for the content of the linked websites, any use of these sites, or the privacy practices of these sites. We do not control third-party websites and applications and are not responsible for their actions or privacy practices.
Your use of the Site constitutes your acceptance of and agreement to this Privacy Notice and all portions hereof. If you do not agree to this Privacy Notice, do not use the Site.
What Personal Information Does Kurv Collect?
Information Provided By You
- Contact information – Our Site may provide you with opportunities for providing us with your contact information in connection with subscribing to Kurv’s periodic newsletters and alerts related to certain financial products, including single stock exchange-traded funds (ETFs). We may collect your name, email address, and any contact information that you provide.
- Shareholder non-public personal information (NPI): In the course of providing products and services to its client (the “ETF”), Kurv may obtain NPI about shareholders of the ETF, which may come from sources such as shareholder transactions, from a shareholder’s brokerage or financial advisory firm, and/or financial professional or consultant. This information may include, but is not limited to, shareholder name, address, phone number, Social Security number, and date of birth.
Information Collected Automatically
When you interact with our Site, we may collect technical information associated with the device you use, such as the type and model, system language, browser type, geolocation and operating system. We may also collect technical identifiers that identify the device you use, such as your Internet protocol (IP) address, identifier for advertisers (IDFA) and other unique identifiers. We may also process information about what you do on our Site, such as how long you visit, what links you click on, what pages you visit, how many times you visit a page, heatmaps and scrolls, and how long it takes for you to come back. To collect this information, we may use cookies and web beacons, and other similar technologies, including Google Analytics.
When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout
Google Analytics: We use Google Analytics as described here. You can prevent your data from being used by Google Analytics on our websites by installing the Google Analytics opt-out browser add-on. If you have accounts with third-party providers, you may be able to control your ad preferences through your account.
To learn more about cookies, please visit https://allaboutcookies.org. As of the “Last Updated” date below, there is no commonly accepted response for Do Not Track (DNT) signals initiated by browsers. To prevent the use of cookies, your browser may have a DNT option in its preferences. If you turn tracking off, we can still identify a device, but we do not keep track of which websites it has been to. Although most web browsers are initially set up to accept cookies, if you prefer, you may decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please understand that certain areas within this Site may not function properly if the web browser does not accept cookies.
How We Use Your Information
Kurv may use your information, including your Personal Information, for a variety of business purposes, including to:
- Provide the products, services or information about the products and services, as may be requested by you;
- Personalize content provided to you on our site or our products and services;
- Process and respond to your requests or to send you other communications;
- Perform statistical analyses and internal research so that we may improve our Site and products, including research, internal analytics, and product development and marketing;
- Market and sell our products and services;
- Comply with legal obligations or legal process;
- Comply with, make claims relating to, or enforce legal rights or obligations, legal process, our policies, government requests, or prudent security or business practices.
- Enforce any applicable agreement with you;
- Monitor for and protect against or prevent fraud or other unauthorized or illegal activity; and/or
- Protect the security and integrity of our organization, the Site, products and services, and service providers.
Kurv does not disclose NPI of shareholders, received from the ETF, to non-affiliated third parties, except as required or permitted by law or as necessary for such third parties to perform their agreements with respect to the ETF. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on shareholder satisfaction and gathering shareholder proxies. The ETF may also retain non-affiliated companies to market the ETF and enter into joint marketing arrangements with them and other companies. These companies may have access to a shareholder’s personal and account information, but are permitted to use this information solely to provide the specific service or as otherwise permitted by law. In most cases, the shareholders will be clients of a third party, but the ETF may also provide a shareholder’s personal and account information to the shareholder’s respective brokerage or financial advisory firm and/or financial professional or consultant.
Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from other third parties and other public records, and use such combined information in accordance with this Privacy Notice.
Your Personal Information is only processed for as long as needed to achieve the purposes listed in this section or up until you withdraw your consent for processing. Kurv will de-identify or delete your Personal Information when it is no longer necessary for the purposes outlined in this section, unless there is:
- An overriding interest of Kurv or any other third party in keeping your Personal Information identifiable; or
- A legal or regulatory obligation or judicial or administrative order that prevents Kurv from de-identifying your Personal Information.
How We Disclose Your Information
Kurv may share and disclose your information, including Personal Information, under the following circumstances:
- With third parties that provide a variety of services on our behalf, including hosting, data management, data storage, and analysis;
- With third party advertising and marketing service providers;
- With business partners that you have a relationship;
- With third parties that may offer joint marketing or promotions;
- With our affiliates to provide the services and to perform marketing;
- To comply with law, a court order, or other legal process, or in connection with a legal investigation;
- As may be necessary to protect the rights and interests of Kurv, our affiliates, third party service providers, and our and their respective employees, clients, users, or any other person or entity;
- To enforce any applicable terms and conditions and/or other agreements;
- In the event of a transfer of ownership of Kurv, merger or other similar transaction (including one in connection with any bankruptcy or similar proceedings); in aggregated or other non-personally identifiable form; and/or
- In accordance with your consent.
Kurv does not sell information that you provide to us with other organizations who intend to use it only to market their products or services to you. Further, Kurv is not and cannot be responsible for the activities or privacy policies of any third party with whom your Personal Information is shared.
What Choices Do I Have About My Personal Information?
Kurv values your privacy and strives to provide you with choices regarding the handling of all Personal Information you choose to provide to us. You may choose not to provide us with your Personal Information if you are uncomfortable with our practices, as set forth in our Privacy Notice.
If you sign up for marketing communications from us and you now wish to unsubscribe, you may do so by clicking on the “unsubscribe” link provided in the communication. Please also note that unsubscribing from future marketing-related messages does not prevent Kurv from sending you administrative messages, as applicable.
Children’s Privacy
The Site is not intended for children under the age of 16 and we do not knowingly collect Personal Information from anyone under 16. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 16 without valid parental consent, we will take reasonable steps to delete it as soon as practicable.
Security of Personal Information
We use appropriate security measures on the Site and within Kurv that are designed to safeguard your Personal Information under our control. Kurv shall use reasonable administrative, technical and physical security controls to protect your Personal Information. While Kurv protects your Personal Information, the confidentiality and security of any communication or material transmitted to or from the Site cannot be guaranteed to be 100% secure at any time. Any transmission of your information is at your own risk. We strongly encourage all users to be careful and responsible about what you choose to provide online.
If you have any reason to believe that your interaction with Kurv through this Site is no longer secure, please immediately notify us using the “Contact Us” section below.
Contact Us
Kurv welcomes your questions and comments about this Privacy Notice or the use of your Personal Information. Please email us at info@kurvinvest.com with any questions or comments.
Last Updated: October November 7, 2022