Consumer Privacy Notice

What does ECP do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share, depend on the product or service you have with us. This information can include:

  • Social Security Number and Account Balances

  • Transaction History and Wire Transfer Instructions

  • Account Transactions and Assets

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons DEI chooses to share, and whether you can limit this sharing.

Reasons we can share your personal information

Can you limit this sharing?

Does ECP share?


For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes - to offer our products and services to you

Yes

No



For joint marketing with other financial companies

No

We don’t share


For our affiliates’ everyday business purposes - information about your transactions and experiences

No

Yes


For our affiliates’ everyday business purposes - information about your creditworthiness

No

We don’t share


For non-affiliates to market to you

No

We don’t share


Who we are

Who is providing this notice?

This notice is being provided on behalf of ECP Private Trust Company an the subsidiaries listed in the “Other important information” section.

What we do

How does ECP protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

Our employees may access personal information only when there is an appropriate reason to do so, such as to administer or offer out products and services.

How does ECP collect my personal information?

We collect your personal information, for example, when you:

  • open an account or make deposits or withdrawals

  • make a wire transfer or provide account information

  • give us your contact information

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  • sharing for affiliates’ everyday business purposes - information about your creditworthiness

  • affiliates from using your information to market to you

  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include companies with an Equilus name; financial companies such as a brokerdealer, investment advisor, and federal savings association; and nonfinancial companies such as a general purpose corporation.

Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • ECP does not share with nonaffiliates so they can market to you.

Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • ECP does not jointly market.

Other Important Information

The information practices we have described above comply with federal law. California and Vermont laws place additional limits on sharing information about their residents. If you are a Vermont or California resident, we will automatically limit the disclosure on your information to affiliated and nonaffiliated third parties as permitted or required by applicable law or regulation.

This notice is being provided on behalf of ECP Trust Company, and the following subsidiaries: Equilus Group Inc. (EGI), ECP Capital Partners, LLC (ECP), ECP Trust Company, and ECP Private Trust Company, collectively “ECP”.