Ivy Distributors, Inc. Privacy Notice for California Residents

Effective Date: July 1, 2020

This privacy notice is for California residents (this “CCPA Notice”) and supplements the information contained in Ivy Distributors, Inc.'s Privacy Policy. We have adopted this CCPA Notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this CCPA Notice.

Applicability of CCPA Notice

The CCPA applies to information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("CCPA personal information").

This CCPA Notice does not apply to, and CCPA personal information does not include, information that is:

  • Employment related and collected from California-based employees, job applicants, shareholders, officers, directors, contractors, or similar individuals;
  • Collected in connection with a written or verbal business-to-business communication or transaction; or
  • Excluded from the CCPA's scope, like:
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA);
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); or
    • De-identified or aggregated information.

Disclosure of Categories, Sources, Purposes and Third Parties

Please see our online privacy policy for a description of the categories of CCPA personal information we have collected, the categories of sources from which we have collected CCPA personal information, the business or commercial purpose for which we have collected CCPA personal information, and the categories of third parties, including our service providers, with whom we have shared CCPA personal information, during the prior 12 months.

If you are a visitor to this Website, you are a resident of California, and you are not:

  • A current or former client,
  • One of our financial advisors,
  • One of our employees or job applicants, or
  • An employee or contractor of another company interacting with us in your business capacity, then you will have the following rights and choices with respect to CCPA personal information.

We do not sell CCPA personal information.

We do not provide any financial incentives permitted by the CCPA or otherwise with respect to CCPA personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their CCPA personal information. This section describes your CCPA rights and explains how to exercise those rights. We will not discriminate against you for exercising any of your CCPA rights.

Access to Specific Information Rights

You have the right to request that we disclose to you the sources and categories of CCPA personal information that we have collected, shared and used, the business or commercial purposes for the collection, sharing and use, and the categories of third parties with whom we have shared and the specific pieces of CCPA personal information we collected about you, over the past 12 months.

Deletion Request Rights

You have the right to request that we delete any of your CCPA personal information that we collected about you. Once we are able to verify your request for the deletion of your CCPA personal information, we will then delete (and direct our service providers to delete) your CCPA personal information from our records, unless an exception applies.

Exercising Access and Deletion Rights

You may make a request for access or for deletion by either:

Verifiable Requests

Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your CCPA personal information. You may also make a verifiable request on behalf of your minor child. You may only make a verifiable request for access twice in a 12-month period.

We must be able to verify your request. You must provide sufficient information in your request to allow us to reasonably verify you are the person about whom we collected CCPA personal information or an authorized representative, which may include:

  • Your name, postal address, telephone number, and
  • A description of your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You can legally authorize a third party to make a request on your behalf by:

  • You having the third party send us a letter, signed by you, certifying that the third party is acting on your behalf and showing proof that the third party is registered with the California Secretary of State; or
  • You and the third party executing and sending us a notarized power of attorney stating that the third party is authorized to act on your behalf. Please note that we may still require you to verify your identity before we process a request submitted by your agent.

We will only use the personal information you provide in your request to verify your identity or authority to make the request. If we cannot initially verify your identity, we may request additional information to complete the verification process. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Responses to Access Requests and Deletion Requests

Most of the CCPA personal information we collect, use and disclose in our business is subject to other privacy laws or is not personal information, as that term is defined in the CCPA. As a result, we will decline all or part of any request that includes information that outside of the scope of or is exempt from the CCPA.

Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we need more time (up to 45 additional days) to respond to your request, we will inform you of the reason and extension period in our response.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to this CCPA Privacy Notice

We reserve the right to amend this CCPA Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, please do not hesitate to contact us by EMAIL: dataprivacy@ivyinvestments.com or US MAIL: Ivy Distributors, Inc., 6300 Lamar Avenue, Overland Park, KS 66202, Attn.: Legal Department.