Effective Date: November 1, 2021
We at IDX Advisors, LLC, along with our affiliates listed in Appendix A of this Global Privacy Policy or here (collectively, “IDX”), respect your concerns about privacy. This Global Privacy Policy describes the types of personal information we obtain, how we use the information, with whom we share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. For the purposes of EU, UK and Swiss data protection laws, IDX is a data controller of your personal information.
This Global Privacy Policy applies to the privacy practices of IDX with respect to its processing of personal information online through IDX’s websites and mobile applications listed in Appendix B of this Global Privacy Policy or here (collectively, the “Sites”), as well as our offline privacy practices (unless they are specifically covered by a separate privacy policy).
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. You can view certain country-specific information by clicking here.
We may obtain information about you in various ways, such as through our Sites, subscription documents and other documents and forms we receive from you or on your behalf.
The types of personal information we obtain include:
contact information (such as name, postal and email address, and telephone number);
date of birth;
information used to create your online account (such as username and password);
information about your transactions with us, our funds or our affiliates; and
other personal information you provide to us, such as through emails, subscription documents and other onboarding documents (that may include Social Security numbers, tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you send us.
In addition to the information listed above, if you are a job candidate and apply for a position with IDX or create an account to do so, or if we conduct a background check in connection with a job opportunity with IDX, we may collect the following types of personal information to the extent permitted by applicable law:
Social Security number, national identifier or other government-issued identification number;
date of birth;
gender;
employment and education history;
language proficiencies and other work-related skills;
citizenship and work authorization status;
military and veteran status;
ethnicity;
self-identified disability status;
results of criminal background checks;
information provided by references; and
other information about your qualifications for employment, such as information contained in your résumé or C.V. and compensation history and related information.
Providing personal information to us is voluntary on your part. If you choose not to provide us with certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of our Sites.
In connection with operating our business and marketing our products and services, to the extent permitted by applicable law, we may obtain personal information from consumer reporting agencies, our related entities, the responsible entities or administrators of managed investment schemes for which we provide services (“Fund”), regulatory or government authorities, industry bodies, professional associations and other third parties.
Information We Obtain by Automated Means
When you visit our Sites, open our emails or interact with IDX-related tools, widgets or plug- ins, we may obtain certain information by automated means, such as through cookies, web server logs, web beacons and JavaScript. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages or applications to web servers and may be used to transmit information back to a web server.
The information we obtain in this manner may include IP addresses, unique device identifiers, browser and operating system characteristics, device characteristics, language preferences, clickstream data, referring/exit URLs, information on actions taken, dates and times of activity and other technical information. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products, services and Sites; (3) tailor our products, services and Sites around your preferences; (4) measure the usability of our products, services and Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our products, services and Sites.
If you wish to disable the storage of cookies on your computer, you may do so by using the settings on your browser or device. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your device. Please note, however, that without cookies, you may not be able to use all of the features of our Sites. For more information on deleting or controlling cookies, visit www.aboutcookies.org.
Information about our cookie practices in the European Union and the United Kingdom (“UK”) is available in Appendix C of this Global Privacy Policy or here. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
Third-Party Analytics Services
We use third-party web analytics services on the Sites, including Google Analytics, Sitecore, Webtrends, and HubSpot Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and web server logs to help us analyze how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) will be shared with or collected directly by these third-party service providers, and other relevant third parties who use the information to evaluate use of the Sites. To learn more about these analytics services and how to opt out (where applicable), please visit:
Google Analytics
Sitecore
Webtrends
HubSpot Analytics
Online Tracking and Interest-Based Advertising
When you use the Sites, we may collect personal information about your online activities, over time and across third-party websites, to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent to the processing of your personal information for direct marketing purposes.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed, and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.
The Sites are not designed to respond to all types of “do not track” signals received from web browsers. To learn how to opt out of ad network interest-based advertising in the United States, please visit www.aboutads.info/choices, www.networkadvertising.org/choices, and preferences-mgr.truste.com.In the European Union, please visit www.youronlinechoices.eu.
How We Use the Information We Obtain
We may use and process the personal information we obtain to:
provide and manage our products, services and Sites;
create, manage and administer accounts you hold with us or with one of our funds;
establish and manage your online account with IDX;
communicate with you and respond to your inquiries;
send you promotional and advertising materials, newsletters and other communications;
verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for our products or services;
manage career opportunities, including for recruitment purposes (such as processing job applications and conducting background checks in accordance with applicable law), employee onboarding and other human resources purposes;
perform data analyses (such as market and customer research);
develop, manage and improve our business, products, services and Sites (such as by enhancing, improving and analyzing our products, services and Sites; developing new products, services, websites and apps; managing our communications; determining and managing the effectiveness of our advertising and marketing; and performing accounting,
auditing, billing and reconciliation activities and other internal functions);
protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities;
conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Global Privacy Policy and our Terms of Use); and
for other purposes required or authorized by law, including other purposes for which you have provided your consent.
As a general matter, we use the personal information we obtain to comply with applicable legal requirements, carry out our contractual obligations and pursue our legitimate interests (such as managing our Sites and client relationships). Where required by applicable law, we obtain consent to process personal information. We also may use the personal information we obtain in other ways for which we provide specific notice at the time of collection.
Information We Share
We do not sell or otherwise share personal information about you, except as described in this Policy. We share your personal information with our affiliates for the purposes identified in this Global Privacy Policy. We also share the information with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that provide web hosting, analytics and other IT services. In addition, we may share your personal information with your authorized representatives.
We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. We reserve the right to transfer personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).
Data Transfers
We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries (such as the United States, United Kingdom, Ireland or Cayman Islands), we will protect that information as described in this Global Privacy Policy.
Your Rights and Choices
We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, ask us to remove your information from our mailing lists or to submit a request regarding your personal information, please contact us as indicated in the How To Contact Us section of this Global Privacy Policy. You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.
To the extent provided by the law of your jurisdiction, you may (1) request access to the personal information we maintain about you; (2) request that we correct, amend, erase or restrict the information; or (3) exercise your right to data portability, by contacting us as indicated below. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
Links to Third-Party Websites, Apps and Other Features
Our Sites may provide links to other websites, apps and features for your convenience and information. The providers of the websites, apps and features may use automated means to collect information regarding your use of the Sites and your interactions with the other websites, apps and features. These websites, apps and features may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. To the extent that any website, app or feature is not owned or controlled by us, we are not responsible for the content, any use of the website, app or feature, or the privacy practices (including cookie practices) of the website, app or feature.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal
information we obtain against unauthorized or unlawful use, disclosure, access, loss, destruction or damage.
Retention of Personal Information
To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Global Privacy Policy or (2) we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.
Children’s Personal Information
The Sites are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Sites. If we become aware that we have collected personal information from a child under the age of 13 through the Sites, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information through the Sites, please contact us as specified in the How to Contact Us section of this Global Privacy Policy.
Updates To Our Global Privacy Policy
This Global Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Policy when it was most recently updated.
How To Contact Us
If you have any questions or comments about this Global Privacy Policy, or if you would like us to update information, we have about you or your preferences, please email us at legal@idx-us.com. You also may write to us at:
U.S.
IDX Advisors, LLC
Attn: Privacy, Legal and Compliance
2201 E. Camelback Rd. Suite 605
Phoenix, AZ 85016
Canada
If you are a resident of Canada, the following Canada-specific provisions apply to our processing of your personal information in lieu of and in addition to the relevant sections of the IDX Advisors Privacy Policy (the “Canada Addendum”). In the event of a conflict between the provisions of the IDX Advisors Privacy Policy and the provisions of the Canada Addendum, the provisions of the Canada Addendum will govern.
References in the Global Privacy Notice and the Canada Addendum to “we”, “us”, “our”, “IDX” and “IDX Advisors, LLC” are references to IDX Advisors, LLC.
We and our U.S. and other affiliates and service providers may disclose information about you (i) if we are required or permitted to do so by applicable law or legal process and (ii) to Canadian, U.S. or other law enforcement authorities, courts and other government officials pursuant to a lawful disclosure request.
If you have questions or concerns regarding our privacy practices or if you would like information regarding our policies and procedures with respect to our service providers outside of Canada, please contact our Privacy Officer, as indicated in the How To Contact Us section of this Global Privacy Policy.
To learn how to opt out of ad network interest-based advertising in Canada, please visit youradchoices.ca/choices.
Appendix A
The privacy practices of the following affiliates of IDX Advisors, LLC are covered by this Global Privacy Policy:
Appendix B
This Global Privacy Policy applies to IDX’s online processing of personal information through the following websites and mobile apps:
mutualfunds.idx-us.com
digitalassets.idx-us.com
www.idxinsights.com
www.consciouscap.com
www.idxadvisors.com
www.idxdigitalassets.com
Appendix C
IDX: Cookie Notice
We at IDX Advisors, LLC, along with our affiliates (collectively, “IDX”), respect your concerns about privacy. This Cookie Notice applies to the IDX websites listed here (collectively, the “Websites”).
Our Websites use cookies, web beacons and similar technologies (collectively, “cookies”) to function effectively. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages or applications to web servers and may be used to transmit information back to a web server.
This Cookie Notice provides you with information about the cookies used on our Websites, their purpose and the choices you can make with regard to the use of cookies.
Cookies used on our Websites
Essential cookies
Some cookies are essential for our Websites to function effectively and to offer our products and services. For example, essential cookies enable you to securely access and navigate within our Websites and to log in. Essential cookies help us understand information, such as your session ID and other server authentication information. In addition, they help us understand whether you have viewed our cookie consent banner.
We currently use the following essential cookies:
These are essential cookies that do not require consent.
__hs_opt_out
This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies. It contains the string “yes” or “no”. It expires in 13 months.
__hs_do_not_track
This cookie can be set to prevent the tracking code from sending any information to HubSpot. It contains the string “yes”. It expires in 13 months.
__hs_initial_opt_in
This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode. It contains the string “yes” or “no”. It expires in seven days.
__hs_cookie_cat_pref
This cookie is used to record the categories a visitor consented to. It contains data on the consented categories. It expires in 13 months.
hs_ab_test
This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before. It contains the id of the A/B test page and the id of the variation that was chosen for the visitor. It expires at the end of the session.
<id>_key
When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login again. The cookie name is unique for each password-protected page. It contains an encrypted version of the password so future visits to the page will not require the password again. It expires in 14 days.
hs-messages-is-open
This cookie is used to determine and save whether the chat widget is open for future visits.
It is set in your visitor’s browser when they start a new chat, and resets to re-close the widget after 30 minutes of inactivity. If your visitor manually closes the chat widget, it will prevent the widget from re-opening on subsequent page loads in that browser session for 30 minutes. It contains a boolean value of True if present. It expires in 30 minutes.
hs-messages-hide-welcome-message
This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed. It contains a boolean value of True or False. It expires in one day.
__hsmem
This cookie is set when visitors log in to a HubSpot-hosted site.
It contains encrypted data that identifies the membership user when they are currently logged in. It expires in one year.
hs-membership-csrf
This cookie is used to ensure that content membership logins cannot be forged.
It contains a random string of letters and numbers used to verify that a membership login is authentic. It expires at the end of the session.
hs_langswitcher_choice
This cookie is used to save the visitor’s selected language choice when viewing pages in multiple languages. It gets set when an end user selects a language from the language switcher and is used as a language preference to redirect them to sites in their chosen language in the future, if they are available. It contains a colon delimited string with the ISO639 language code choice on the left and the top level private domain it applies to on the right. An example will be “EN-US:hubspot.com”. It expires in two years.
__cfduid
This cookie is set by HubSpot’s CDN provider, Cloudflare. It helps Cloudflare detect malicious visitors to your website and minimizes blocking legitimate users.
It may be placed on your visitors’ devices to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare’s security features. Learn more about this cookie from Cloudflare. It is a session cookie that lasts a maximum of 30 days.
__cfruid
This cookie is set by HubSpot’s CDN provider because of their rate limiting policies. Learn more about Cloudflare cookies. It expires at the end of the session.
Our Websites may use third-party analytics and advertising cookies, for example, to help create reports and statistics on the performance of our Websites and marketing campaigns and to present you with content tailored to your interests. Analytics and advertising cookies help us understand information such as device ID, IP address, browser type, operating system, referring URLs, time and date of activity, actions taken on our Websites (including site searches), language preferences, city and country information and demographic data.
We currently use the following analytics and advertising cookies:
wp-settings-1
WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
wp-settings-time-1
WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
pvisitor
These are non-essential cookies controlled by the cookie banner. If you’re a visitor to a site supported by HubSpot, you can opt out of these cookies by not giving consent.
_hssc
This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. It expires in 30 minutes.
_hssrc
Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session. It contains the value “1” when present. It expires at the end of the session.
_hstc
The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). It expires in 13 months.
_hubspotutk
This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor.
It expires in 13 months.
sc_analytics_global_cookie
Cookie used to identify a user’s repeat visits to a website
analytics_session_cookie
Cookie used to identify a user’s sequence of HTTP requests to a website
wt_fpc
Cookie used to collect information about how a specific webpage was reached (i.e., user path through a website)
webtrends_id
Cookie used to collect information about a user’s visit to a website
acookie
Cookie used to collect information about a user’s interactions with a website
You can stop cookies from being downloaded on your computer by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie and how to disable existing cookies. On Microsoft Internet Explorer, this can be done by selecting “Tools/Internet Options” and reviewing your privacy settings or selecting “delete cookies.” You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. Please note, however, that without cookies, you may not be able to take full advantage of all features on our Websites.
Contact Us
If you have any questions or comments about this Cookie Notice, please email us at: legal@idx-us.com.
Distributed by Foreside Fund Services, LLC which is not affiliated with IDX Funds or IDX Advisors LLC. There are risks involved with investing including the possible loss of principal. Diversification does not guarantee investment returns or eliminate the risk of loss. Past performance does not guarantee future results. Investors should carefully consider the investment objectives, risks, charges and expenses of the fund before investing. To obtain a prospectus containing this and other important information, please visit the fund page to download a prospectus online or here. Read the fund’s prospectus carefully before you invest.
The BTIDX Fund actively invests in bitcoin futures contracts and other instruments that provide exposure to bitcoin futures. The Fund is a new mutual fund and has a limited history of operations for investors to evaluate. Additional risks associated with the Fund include, but are not limited to: Futures Risk: The Fund’s use of futures involves risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments. Investments in futures involve leverage, which means a small percentage of assets invested in futures can have a disproportionately large impact on the Fund. Concentration Risk: The Fund is concentrated in the Bitcoin industry. The Fund’s concentrated investment exposure involves risks different from, or possibly greater than, the risks associated with investing in a fund with exposure to a broader range of industries. The concentration risk of the Fund includes, but is not limited to, the potential for greater volatility and the potential for greater loss of investment capital than a diversified fund. The Fund may be susceptible to financial, economic, political or market events, as well as government regulation, impacting the Bitcoin industry. Fluctuations in the price of Cryptocurrencies, specifically Bitcoin and Bitcoin industry companies, often dramatically affects the profitability of the Bitcoin Industry and therefore potentially the Fund. Cryptocurrency Risk: Cryptocurrency (notably, Bitcoin), often referred to as “virtual currency” or “digital currency,” operates as a decentralized, peer-to-peer financial exchange and value storage that is used like money. The Fund may have concentrated exposure to Bitcoin, a cryptocurrency, indirectly through an investment in CME Bitcoin Futures and vehicles that the fund’s manager, in its sole and absolute discretion, determines to be Bitcoin Industry companies or investments. Cryptocurrencies operate without central authority or banks and are not backed by any government.
The COIDX Fund is a new mutual fund and has a limited history of operations for investors to evaluate. Additional risks associated with the Fund include, but are not limited to: Investment Concentration Risk: The Fund is concentrated in Commodity Futures and Commodity Industry companies. The Fund’s concentrated investment exposure involves risks different from, or possibly greater than, the risks associated with investing in a fund with exposure to a broader range of industries. The concentration risk of the Fund includes, but is not limited to, the potential for greater volatility and the potential for greater loss of investment capital than a diversified fund. The Fund may be susceptible to financial, economic, political or market events, as well as government regulation, impacting the Commodity industry. Fluctuations in the price of Commodities often dramatically affects the profitability of the Commodities Industry and therefore potentially the Fund. Futures Risk: The Fund’s use of futures involves risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments. Investments in futures involve leverage, which means a small percentage of assets invested in futures can have a disproportionately large impact on the Fund.
Other risks associated with investing in the funds include: Geographic Concentration Risk: The Funds may be particularly susceptible to economic, political, regulatory or other events or conditions affecting countries within the specific geographic regions in which the Fund invests. Liquidity Risk: Liquidity risk exists when particular investments of the Fund would be difficult to purchase or sell, possibly preventing the Fund from selling such illiquid securities at an advantageous time or price, or possibly requiring the Fund to dispose of other investments at unfavorable times or prices in order to satisfy its obligations. Leverage Risk: The value of your investment may be more volatile if the Fund borrows or uses instruments, such as derivatives, that have a leveraging effect on the Fund’s portfolio. Equity Market Risk: Equity markets can be volatile, and the prices of common stocks can fluctuate significantly. Derivatives Risk: The use of derivative instruments involves risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments. Foreign Investment Risk: Foreign investing involves risks not typically associated with U.S. investments, including adverse fluctuations in foreign currency values, adverse political, social and economic developments, less liquidity, greater volatility, less developed or less efficient trading markets, political instability and differing auditing and legal standards. Portfolio Turnover Risk: The frequency of the Funds transactions will vary from year to year. Higher costs associated with increased portfolio turnover may offset gains in a Funds performance. ETF Risk: ETFs are subject to investment advisory fees and other expenses, which will be indirectly paid by the Fund. As a result, your cost of investing in the Fund will be higher than the cost of investing directly in ETFs and may be higher than other mutual funds that invest directly in stocks and bonds. ETFs are listed on national stock exchanges and are traded like stocks listed on an exchange. Model and Data Risk: Given the complexity of the investments and strategies of the Fund, the adviser relies heavily on quantitative models and information and data both proprietary as well as supplied by third parties (“Models and Data”). Models and Data are used to rank securities and derivatives, provide risk management insights, and to assist in managing the Fund’s investments.
