Privacy Policy

Updated: May 2025

ImpactVest Group Inc. (“ImpactVest,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, store, and disclose your personal information. By accessing or using our services, including our website and blockchain-based platforms, you consent to the collection and use of your personal data as described in this Privacy Policy.

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1. Introduction

ImpactVest is a U.S.-registered investment adviser focused on delivering impact-aligned investment strategies. We operate at the intersection of AI, blockchain, tokenization, and environmental, social, and governance (ESG)-integrated approaches. Our services include institutional investments, co-developed financial products, and innovative platforms leveraging blockchain technology. This Privacy Policy governs the collection, use, and protection of your personal data as part of our operations.

2. Information We Collect

We collect various types of personal information to provide our services, including but not limited to:

• Personal Identification Information: Name, address, email address, phone number, and other contact details.
• Financial Data: Investment preferences, transaction history, financial position, and investment-related information.
• Communication Data: Emails, contact form submissions, or other direct communications with us.
• Blockchain and Tokenization Data: Transaction history and related data within blockchain-based platforms.
• Technical Data: IP address, browser type, operating system, and other data automatically collected via our website and digital platforms.

Collection Methods: We collect personal data through direct interactions with us (e.g., during registration, transactions, or communications), through our website, and via third-party services that support our platforms.

3. Use of Information

The information we collect is used to:

• Provide personalized investment services and solutions, including access to tokenized assets, impact-aligned funds, and ESG-integrated strategies.
• Communicate with investors and prospective clients, providing updates on our products and services.
• Ensure compliance with applicable regulatory and legal obligations, including anti-money laundering and tax reporting requirements.
• Enhance user experience across our blockchain-based platform and ensure secure, transparent transactions.
• Manage our business operations, including research and development, marketing, and partnerships.

4. Data Sharing and Disclosure

We may share your personal information with:

• Affiliates and Subsidiaries: ImpactVest Group Inc. and its affiliates (including ImpactVest Management Company, LLC and any future spin-offs or subsidiaries).
• Strategic Partners and Service Providers: Financial institutions, institutional investors, co-investors, technology partners, and other parties that help us deliver services.
• Regulatory and Legal Authorities: When required by law, regulation, or to protect the rights and safety of users or our platform.

We ensure that any third parties receiving your personal data adhere to appropriate data protection standards in line with this policy.

5. Security of Data

We implement technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, or alteration. These measures include:

• Encryption of sensitive financial data.
• Secure data storage systems and access controls.
• Regular security audits and assessments.

While we strive to safeguard your data, please note that no data transmission over the internet can be guaranteed as 100% secure. We cannot ensure the absolute security of data transmitted through our platforms.

6. International Data Transfers

As a global business, we may transfer your personal data to, store it in, and process it in jurisdictions outside your country of residence, including the United States. These jurisdictions may have different levels of data protection laws. By using our services, you consent to the transfer and processing of your personal information in accordance with this Privacy Policy.

7. User Rights and Choices

Under applicable data protection laws, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectify: Correct any inaccuracies in the personal information we hold.
• Delete: Request the deletion of your personal data, subject to legal obligations.
• Restrict or Object: Limit or object to the processing of your personal information.
• Withdraw Consent: If you have provided consent for data processing, you can withdraw it at any time.

To exercise these rights, please contact us at the details provided below. We may retain certain data for legal or regulatory reasons, including records of transactions or investments.

8. Blockchain and Tokenized Asset Data

As part of our blockchain and tokenization services, we may collect transaction data and related information that is stored on distributed ledger systems. This data is immutable and may be accessible to users, regulators, or other authorized parties. Personal data related to blockchain transactions may be subject to different privacy considerations, and users should carefully review these aspects before engaging with our platforms.

9. Changes to this Privacy Policy

ImpactVest may update this Privacy Policy from time to time to reflect changes in our services, regulatory requirements, or business practices. We will post the updated policy on our website and notify you of material changes as required by law. The updated Privacy Policy will be effective as of the date indicated at the top of this page.

10. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:

• Email: compliance@impactvest.com
• Phone: (520) 412-5253
• Address: #460, 447 Broadway, 2nd Floor, New York, NY 10013, United States

Effective Date: May 2025