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Privacy

Privacy Policy

Plain answers about what we collect, why, and how it is protected. Last updated July 8, 2026.

Who we are

ETFcomply (“we”, “us”) provides a compliance system of record for ETF issuers. Our customers are firms; the data we process belongs to those firms and is processed on their instructions. Contact: broth@thoranalytics.com.

What we collect

  • Account data: name, work email address, and a salted password hash for people who sign in.
  • Fund data: fund records, holdings, NAV and related figures supplied by your fund administrator or uploaded by your firm.
  • Email-derived documents: if your firm connects a mailbox, we read messages on a read-only basis to identify fund documents (administrator reports, index files, filings correspondence), store copies of relevant attachments in your firm’s vault, and record message metadata (sender, subject, date) for classification and audit.
  • Usage records: an append-only audit log of actions taken in the product, kept because our customers are regulated and must evidence their work.

Google user data (Gmail API)

When a firm connects a Google mailbox, ETFcomply requests the read-only Gmail scope (gmail.readonly) plus basic profile email. We use this access only to: (1) list and read messages so we can identify fund-related documents, (2) download relevant attachments into the firm’s document vault, and (3) record message metadata for classification and audit. We do not send email, modify or delete messages, and we never use email content for advertising or to train generalized machine-learning models.

ETFcomply’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

OAuth tokens are stored encrypted (AES-256-GCM) and are used only by the sync service. You can disconnect a mailbox at any time in Settings, which stops all access; you can also revoke ETFcomply’s access from your Google Account security settings. On disconnection we delete the stored tokens. Documents already filed into your firm’s vault remain, because they are part of your firm’s books and records.

Microsoft 365 mail data

When a firm connects a Microsoft 365 mailbox we request read-only mail access (Mail.Read) and apply the same rules as for Google data: read-only, used solely to identify and archive fund documents, tokens encrypted at rest, disconnect at any time, no advertising use, no model training.

How data is protected

  • Data is segregated per firm; every query and storage key is scoped to your firm.
  • Credentials and OAuth tokens are encrypted at rest with AES-256-GCM.
  • Transport is TLS. Document downloads use short-lived signed URLs.
  • Compliance records and audit logs are append-only and tamper-evident.

Sharing

We do not sell personal data and we do not share it for advertising. Data is shared only with infrastructure subprocessors needed to run the service (cloud hosting, managed database and object storage) under their standard data-protection terms, or when your firm exports it (for example an examiner bundle you generate and download).

Retention and deletion

Because the product exists to keep regulated books and records, documents follow the retention classes your firm configures (for example six-year retention under Rules 31a-1 and 31a-2). Account data is deleted on request when it is no longer needed for those records. Firms can request full deletion of their tenant by contacting us; we honor it subject to the retention obligations your firm instructs us to keep.

Your choices

  • Disconnect any connected mailbox or administrator feed at any time in Settings.
  • Revoke ETFcomply’s OAuth access from your Google or Microsoft account settings.
  • Ask us to correct or delete account data: broth@thoranalytics.com.

Changes

We will post any changes to this policy on this page and update the date below. Material changes will be announced to account owners by email.