Privacy Policy

Our mission as Adaptive Investment Solutions, LLC is to help Financial Advisors (“you”) understand, communicate, and improve risk management for investment portfolios.

This Privacy Policy covers your use of our website, Adaptive (“Website”), and any other services we offer on our website. This Privacy Policy describes:

  • How to contact us if you have questions;
  • The information that Adaptive collects from you in any form, including when you interact with the Website;
  • How we collect, use and disclose the information we receive, including sharing that information with third parties;
  • How we store and secure information.


“Services” are the software, web pages, analysis, and any information generally accessible through a website that we host, such as, as well as any updates or modifications we make;

“Companies” are corporations that are publicly traded on stock markets or Asset Managers that manage mutual funds and/or ETFs;

“Financial Advisors” are Registered Investment Advisors, typically carrying Series 65 credentials, who subscribe to Adaptive for annual services that help them understand, communicate, and improve risk management for investment portfolios;

“Clients” are clients of Financial Advisors;

“Users” are all users of Adaptive’s services, including Financial Advisors;

“Petitions” are informal petitions that Users can create to support an environmental and/or social issue.

Information We Collect

Information you Provide Us

We collect information you voluntarily provide us when you use the Website. This information may include:

  • Account Information. To create an account as a Financial Advisor, you must provide an email address and password. Your email and password are not public. We store your user account preferences and settings.
  • Content you submit. We collect the content you submit to us. This includes Portfolios that you create and portfolio information you upload to generate an impact report. Your content may include text, links, and images. You may also choose to upload information about yourself and your practice to a public profile, which is viewable by Users that are not Clients of Financial Advisors subscribing to Adaptive.
  • Actions you take. We collect information about the actions you take on the Website.
  • When you Communicate with us. You may choose to provide other information directly to us. For example, when you suggest a feature or report a bug, or otherwise communicate with us.

Financial Advisors may use Adaptive’s services without sharing any personal information about clients or prospective clients (“Clients”). However, Financial Advisors may choose to use the Adaptive tools for prospective clients, or initiate a technology integration with a custodian or service provider to sync current client accounts. In this case, Adaptive may receive information about a Client and that Client’s portfolio. Adaptive stores the following information to allow Financial Advisors to create and display impact reports customized to a particular existing or prospective client:

  • Names of positions in the Client’s portfolio.
  • Quantities of positions in the Client’s portfolio.
  • Name of the Client.
  • Risk Preferences.
  • Email addresses.

Any personal information about any Client will be visible to that Client’s Financial Advisor, but will not be visible to anyone other than the Financial Advisor or an administrator for their rm. Any client information input from a Financial Advisor will not be used by Adaptive in any way besides providing services to that Financial Advisor to communicate with their client.

When you use or access the Website, we collect information that includes:

  • Log and Usage Data. We may log information when you access and use the Website. This may include your IP address, browser type, operating system, referral URLs, device information, pages visited, links clicked, user interactions, hardware settings, and search terms.
  • Information Collected from Cookies. We may receive information from cookies, which are pieces of data your browser stores and sends back to us when making requests. We use this information to improve your experience, understand user activity, and improve the quality of the Website. For example, we store and retrieve information about your preferred language and other settings.
  • Information Collected from Integrations. We may receive information about you from third-party websites that integrate with the Website. For example, like many websites, we use Google Analytics to get a better understanding of our audience.

How We Use Information

We use information about Users, including you, the Financial Advisor, and any Clients whose information you may sync with Adaptive, to:

  • Provide, maintain, and improve the Website;
  • Personalize your experience because your information helps us to better respond to your individual needs;
  • Research and develop new services;
  • Help protect the safety of the Website and our users, which includes blocking suspected spammers, addressing abuse, and enforcing the Terms of Service;
  • Send you technical notices, updates, security alerts, and other support and administrative messages or to otherwise communicate with you about the use of the Website;
  • Monitor and analyze trends, usage, and activities in connection with our Services;
  • Address any claim or dispute related to your use of the Website, or as otherwise allowed by applicable law.

Legal Basis for Using Your Personal Information

We will only use your personal information and your Clients’ personal information as permitted by law. Under most circumstances, we will use your personal information for the following permissible reasons:

  • To perform the contract we are about to enter into or have entered into with you (e.g. when we provide you Services);
  • To carry out our legitimate interests provided that your interests and fundamental rights do not override those interests (e.g. so Adaptive can carry out its mission);
  • When you provide consent (e.g. when you request that we receive information from a technology integration partner; you have the right to withdraw that consent at any time by contacting us);
  • To comply with a legal or regulatory obligation.

How Information About You is Shared

When you use the Website, certain information may be shared with other users and the public, as follows. Information about your clients will never be accessible by the public, and can only be viewed by Financial Advisors in your organization that already have access to the information through custodian and/or service provider relationships.

  • When you publish your profile, the content of that profile will be public.
  • Anonymized, aggregated statistics about User activities may be reported to other users or potential users of Adaptive. These statistics must not be able to reasonably identify any individual.
  • We may offer social sharing features or other integrated tools that let you share content or actions you take on the Website with other media. These are optional tools; you only use them if you want to. Your use of these features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features (e.g., Tumblr, Facebook, Pinterest, and Twitter).

We will not share, sell, or give away of our Users’ personal information to third parties, unless one of the following circumstances applies:

  • To comply with the law. We may share information (and will attempt to provide you with prior notice, to the extent legally permissible) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements.
  • To enforce our policies and rights. We may share information if we believe your actions are inconsistent with our Terms of Service, Adaptive policies, or to protect the rights, property, and safety of ourselves and others.
  • With other users, with your consent. We share certain information among Financial Advisors. For example, Financial Advisors who choose to sync with their client accounts are able to view their clients’ holdings so as to generate impact reports.
  • With our partners. We may share information with vendors, consultants, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out work for us. The partner’s use of personal data will be subject to appropriate confidentiality and security measures.
  • Aggregated or de-identified information. We may share aggregated or de-identified information, which cannot reasonably be used to identify you.

Ads and Analytics Partners

In general, Adaptive does not primarily rely on revenue from online display advertising. Nevertheless, we may partner with third parties as marketing affiliates, in the context of providing you a relevant link to sign up for a good or service that enhances your use of the Adaptive. If you decide to visit and submit any information to a third party, you are subject to its privacy policy and practices and not this Privacy Policy.

Marketing Partners. We may provide a unique link to a marketing partner, for you to sign up to a product or service relevant to Adaptive. We disclose such relationships at the location where you are able to click on the link. We do not share your Adaptive account details with these partners. This means that we do not share your individual account browsing habits. Adaptive cannot see these partners’ cookies, and marketing partners will not see Adaptive cookies.

Analytics Partners. We use analytics partners (such as Google Analytics) to help analyze usage and traffic for our Services. As an example, we may use analytics partners to analyze and measure, in the aggregate, the number of unique visitors to the Website.

Your Options Regarding Personal Data

You have choices about how to protect and limit the collection, use, and disclosure of information about you.

  • Change Your Information. You can change or update your information with us at any time by contacting us, or through the tools we provide you to do so, located on your user dashboard.
  • Deleting your Account.You may delete your account information at any time from the user preferences page. When you delete your account, all personal information about your clients will also be deleted, and your profile is no longer visible to anyone.
  • Access or Object to Use of Your Information. In addition to the opt-out and edit options, if you are in a country within the European Economic Area (EEA), you can request access to your information, and object to or seek to restrict our processing of your information in certain circumstances. Please note that you can always ask us to delete your information from all marketing communications or subscriptions at any time.

If you are in the European Economic Area, you have the right to request access to, recti cation of, or erasure of your personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing; and to withdraw consent for processing where you have previously provided consent. These rights can be exercised using the information provided under “Your Options” above. EEA users also have the right to lodge a complaint with their local supervisory authority.

Controlling Linked Services, Cookies, Analytics, Do Not Track

  • Controlling the Use of Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first- and third-party cookies. Please note that if you choose to remove or reject cookies, the availability and functionality of the Website will become impaired.
  • Controlling Analytics. Some analytics providers we partner with may provide speci c opt-out mechanisms and we may provide, as needed and as available, additional tools and third-party services that allow you to better understand cookies and how you can opt-out. For example, you may manage the use and collection of certain information by Google Analytics.
  • Do Not Track. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. There is no accepted standard, however, for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

Information Security

We take measures to protect information about you from loss, theft, disclosure, alteration, destruction, misuse and unauthorized access. For example, we use HTTPS while information is being transmitted. We also enforce technical and administrative access controls to limit which of our employees have access to non-public information. Our security practices are vetted for a high standard of rigor by our integration partners.

Data Retentions

We store the information we collect for as long as it is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.


The Website is intended for individuals over the age of 18 only. Individuals under the age of 18 may not create an account or otherwise access or use the Website.


We are based in the United States, and we process and store information on servers located in the United States. We may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers.


We may change this Privacy Policy from time to time. If we do, we will notify you through the contact information you provided when signing up on the Website. At that point in time you can then decide whether you would like to continue to use the Website.

Contact Us

The goal of this Policy document is to clarify your questions. We are always seeking to be more clear. Please email us at if you have any questions or suggestions regarding this Privacy Policy.