Privacy Policy

If you become a shareholder of the Fund, certain nonpublic personal information collected in connection with your shareholder relationship is governed by the Gramm-Leach-Bliley Act ("GLBA") and SEC Regulation S-P and is addressed in the Fund's privacy notice, which is included in the Fund's prospectus. Ivy Invest Corporation is also subject to Regulation S-P in its capacity as an SEC-registered investment adviser.

Certain information collected in connection with a Fund shareholder relationship is subject to federal and state financial privacy laws and the Fund's privacy notice. This Privacy Policy primarily addresses information collected outside that relationship, including website, application, communications, analytics, and advertising information.

If this Privacy Policy and the Fund's privacy notice address the same information inconsistently, the Fund's privacy notice controls with respect to information governed by that notice.

Information you provide to us. Depending on how you interact with the Services, this may include:

• Contact information: name, email address, phone number, mailing address
• Account credentials: password and authentication data
• Identity-verification information: date of birth, Social Security number or other government identifier, and government ID documentation, which we use for know-your-customer, anti-money-laundering, fraud-prevention, and related compliance purposes
• Beneficiary information for custodial accounts: the minor beneficiary's name, date of birth, and Social Security number, provided by the adult custodian (see Section 8)
• Financial information: bank account details used to fund your account, and income and net worth ranges you provide during signup, which we use for internal analytics
• Account-type-specific information: depending on the type of account you open or fund, information such as details of external accounts you transfer from (for example, a retirement account at another institution), trust or entity documentation, and beneficiary designations
• Tax forms and electronic signatures
• Communications: messages you send us, survey responses, and support requests
• Newsletter and marketing preferences

Information collected automatically. When you use the Services, we and our service providers automatically collect device and usage information, including IP address, browser and device characteristics, device identifiers, operating system, referring URLs, approximate location derived from IP address, pages viewed, actions taken within the Services, and session recordings as described in Section 5. We collect this through server logs, cookies, pixels, software development kits, and similar technologies.

Information from other sources. We may receive information from identity verification and KYC providers, banking and payment infrastructure providers, and advertising and analytics platforms, in order to verify your identity, process transactions, measure our marketing, and keep our records accurate.

We use personal information to provide and administer the Services and your account; verify your identity and comply with anti-money-laundering, know-your-customer, tax, and other legal obligations; process subscriptions, repurchases, and other transactions; respond to inquiries and provide support; and send service, regulatory, and (unless you opt out) marketing communications.

We also use information to measure and improve the Services and our marketing; conduct analytics and advertising; detect and prevent fraud, abuse, and security incidents; and enforce our terms.

We do not sell personal information in exchange for money. We may disclose online identifiers and activity information to analytics and advertising providers for measurement and advertising purposes as described in this policy. Some privacy laws may characterize certain advertising-related disclosures as "selling," "sharing," or targeted advertising.

We share personal information in the following circumstances:

Service providers. We share information with vendors that perform services on our behalf under contracts limiting their use of the information, including: transfer agent and fund administration providers; custodians and banking partners; identity verification and KYC services; cloud hosting and infrastructure providers; analytics providers; email and communications platforms; and customer support tooling.

Advertising partners. If you interact with our website or advertising, we may share identifiers and activity data with advertising platforms to measure and improve our campaigns and to deliver ads that may be relevant to you. Your browser and device settings may allow you to limit some of this collection, as described in Sections 5 and 9.

Legal disclosures. We may disclose information to regulatory, governmental, tax, judicial, and law-enforcement authorities as required or permitted by law, and where disclosure is necessary to exercise or defend legal claims.

Business transfers. In connection with a merger, financing, acquisition, or sale of all or part of our business, personal information may be transferred as part of that transaction, subject to applicable law and appropriate confidentiality protections.

We do not share mobile phone numbers or SMS opt-in data with third parties or affiliates for their own marketing purposes.

We use cookies, pixels, and similar technologies to operate the Services, remember your preferences, understand how the Services are used, and measure advertising.

• Essential technologies are necessary for core Service functions, such as keeping you signed in.
• Analytics help us understand how visitors use our website and app so we can improve them. We use Google Analytics; for supported web browsers, Google provides an opt-out browser add-on at https://tools.google.com/dlpage/gaoptout, and Google's privacy practices are described at https://policies.google.com/privacy. We also use other analytics providers that collect usage data on our behalf.
• Session replay technology captures certain interactions with our website and app, such as clicks, scrolling, and page navigation, to help us diagnose technical issues and improve usability. These tools are configured to mask or exclude designated sensitive fields and pages.
• Advertising technologies, such as the Meta pixel and similar tools, help us measure campaigns and reach audiences on third-party platforms.

You can control cookies through your browser settings, and your device may provide controls for mobile advertising identifiers.

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal and regulatory obligations, prevent fraud, resolve disputes, and enforce our agreements. Retention periods vary depending on the nature of the information and the applicable requirements. Certain fund, shareholder, transaction, advertising, and communications records must be retained for periods prescribed by federal securities laws, and some records may be retained permanently. When information is no longer required, we delete, deidentify, or securely dispose of it in accordance with our policies and applicable law.

We maintain administrative, technical, and physical safeguards designed to protect personal information, consistent with our obligations under applicable law, including encryption of data in transit, access controls, and oversight of service providers that handle personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

The Services are intended for adults. Only individuals 18 or older may open an account, and we do not knowingly collect personal information directly from children under 18.

We do collect personal information about minors in connection with custodial investment accounts (such as UGMA/UTMA accounts). This information — including the minor beneficiary's name, date of birth, and Social Security number — is provided to us by the adult parent or custodian, not collected from the minor, and is required for account administration and tax reporting. We handle it in accordance with this policy and the Fund's privacy notice, and it is subject to the same safeguards and retention requirements as other account information.

If you believe a child under 18 has provided personal information directly to us outside of a custodial account relationship, contact us at support@ivyinvest.co and we will take appropriate steps to delete it, unless we are required or permitted by law to retain it.

You can unsubscribe from marketing emails using the link in any marketing email, and you can opt out of marketing text messages by replying STOP; we will still send service and regulatory communications related to your account, including authentication messages. You can review and update your account information in your account settings. Browser and device controls that may limit certain cookies and advertising technologies are described in Section 5.

Depending on where you live, applicable law may give you certain rights regarding your personal information. Regardless of whether a particular law applies, we will make reasonable efforts to honor requests to access, correct, or delete personal information, or to limit its use for advertising — subject to identity verification, applicable exceptions, and legal and regulatory retention requirements.

Certain information collected in connection with Fund shareholder relationships is governed by the GLBA, Regulation S-P, and the Fund's privacy notice; federal securities recordkeeping requirements may limit our ability to delete that information.

To make a request, email support@ivyinvest.co. We may need to verify your identity before completing certain requests. We will not discriminate against you for making a request.

Some browsers transmit "Do Not Track" signals. Because no uniform standard currently governs these signals, we do not respond to them. Our analytics and advertising providers may collect information about your activities over time and across different websites or online services.

We may update this Privacy Policy from time to time. The date at the top identifies when the current version took effect. If we make material changes, we will notify you by posting a prominent notice on the Services or by contacting you directly.

Email: support@ivyinvest.co

Ivy Invest Corporation
2261 Market St #5190
San Francisco, CA 94114
United States