Terms of Service
Last Updated: December 24, 2019
Threadvest, LLC (“Threadvest”) is an independent company that is not affiliated with any other financial institution. Threadvest is not a stock, bond or any other trading platform. This statement includes disclaimers, disclosures and other information necessary for users to better understand the services we provide and its limitations.
Your access and use of the https://threadvest.com website, the Threadvest ETF Miner described below, and any other services provided through the website (collectively referred to as the “Threadvest Service” or the “Service(s)”) are subject to these Terms of Service (this “Agreement”). By using the Threadvest Service, you agree to be bound by this Agreement and to use the Threadvest Service in compliance with this Agreement.
The terms “you,” “your,” and “yours” refer to you, the user of the Threadvest Service. The terms “Threadvest,” “we,” “us,” and “our” refer to Threadvest, LLC. We may periodically make changes to this Agreement. It is your responsibility to review the most recent version of this Agreement frequently and remain informed about any changes to it.
An “Exchange-traded fund” or “ETF” is a marketable security that tracks a certain index and trades on major stock exchanges.
Description of the Threadvest Service
The Threadvest Service offers users:
- Access to our powerful and convenient Threadvest ETF Miner (“ETF Miner”) as a tool to search currently trending ETFs based on users’ specific interests and investment goals. The ETF Miner employs proprietary technology to reveal ETFs that match your preferences. For more information regarding our ETF Miner, see below
- Articles, blog posts, general tips, and other educational materials; and
- Information relating to third-party products or services that you may be interested in (“Threadvest Offers”).
The Threadvest Service is provided to you without charge (it is free) and is meant to provide you with information to allow you to select ETFs that match your investment preferences.
The ETF Miner provides information about Exchange Traded Funds (heretofore addressed as “ETFs”) likely to match your preferences. Among other things, the proprietary element covers topics such as performance, replication structure, number of holdings etc, undertaken by Threadvest to streamline the user experience. Users are solely responsible for their own trading decisions, which may be conducted on the trading platform of their choice. Users should conduct further research and/or consult a professional investment adviser that is aware of the user’s circumstances. Before investing in an ETF or any other investment, consider its investment objective, risks, charges and expenses. Read the prospectus, offering circular or, summary prospectus which contains important information you need to know before investing.
The ETF Miner allows you to rank the selected criteria along with our own to find several ETFs that may match the characteristics you seek. The inputs entered are at the sole discretion of the user, and all screens that display possible options are solely for the convenience of the user. All information obtained from the ETF Miner is for informational purposes only and should not be considered investment advice or guidance, an offer of or a solicitation of an offer to buy or sell securities, or a recommendation or endorsement by Threadvest of any security or investment strategy. Threadvest is not endorsing any particular ETF nor is it indicating that it has evaluated all of the ETFs one can choose. ETF shares are bought and sold at a market price, which may be higher or lower than their NAV, and may not be individually redeemed from the fund or by the issuer. ETFs may cease to exist or change its characteristics based on the ETF issuer’s decision or a change to the strategy the issuer decides to make. Threadvest makes no guarantees that the information provided in the ETF Miner is accurate, complete, or timely, and does not provide any warranties regarding results obtained from using the ETF Miner.
ETFs, Products and related instruments or any other types of instruments or securities mentioned throughout this site are not being offered through Threadvest. You may make particular decisions to invest in concert with, or under the advice of an adviser you choose or a platform that you have chosen to conduct investment activities. Any investment or one as part of a diversified or un-diversified portfolio, may not protect you from losses. An investment in ETFs, structured as a mutual fund, unit investment trust or other structure, involves the risk of losing money and should be considered as part of an overall program, not a complete investment program. Risks related to ETFs may come from not being diversified, price volatility, competitive industry pressure, international political and economic developments, possible trading halts, changes to indices or other reasons. The expenses associated with owning an ETF typically include costs for management, administration, custody, auditing, brokerage fees, re-balancing costs and what you pay through trading spreads. ETF bid/ask spreads widen and narrow during the day based on volume, trader/investor decision-making, time of day, underlying credit, news and other factors affecting underlying securities or indices. Before you buy or sell, review how the bid/ask spread has changed over time. Small spreads generally indicate lower costs to trade, however be mindful that a thinly traded ETF could also have a narrow spread at times. You should understand the total cost of investing prior to making an investment decision.
Some “ETFs” create leveraged or inverse portfolios that may use margin to short stocks or other assets (inverse) or use margin and/or derivative instruments to increase leverage. Most of these types of securities or instruments are Exchange Traded Notes (ETNs) and not true ETFs. An ETN is a bond or like position that may trade like a stock, but is typically backed by an issuer. These instruments are frequently referred to as an ETF but are designed to replicate or amplify the return of whatever asset they are tracking. On average, ETNs are more expensive than ETFs and include the credit risk that the issuer will be unable to back the ETN during a period of market stress.
Before investing, know the difference between an ETF, which usually owns the underlying securities, versus other exchange-traded products, which may have different structures and tax reporting requirements. Most ETFs are taxed as capital gains. Some that hold derivatives could require a K-1. Exposure to commodities obtained in an ETF or similar instrument (particularly precious metals), may subject you to the collectible tax rate. You should consult with your tax advisor before making an investment in an ETF that may include the characteristics mentioned in this paragraph or others mentioned throughout Threadvest’s site and specifically with respect to the ETF Miner.
You must be 18 years of age or older to use the Threadvest Service. It is not intended for those under the age of 18. Use of the Service is void where prohibited. You represent and warrant that the profile information you submit is true and accurate and that your use of the Service will not violate any applicable law or regulation. You represent and warrant that you are 18 years of age or older and are fully able and competent to enter into, and abide by the terms of this Agreement.
License to Use the Service
Subject to this Agreement, we grant to you a limited, personal, non-exclusive, non-transferable license to use the Service for personal, noncommercial purposes. Your right to use the Service is limited by the terms of this Agreement. Except for this license granted to you, we retain all right, title, and interest in and to the Threadvest Service, including all related intellectual property rights. The Threadvest Service is protected by applicable intellectual property laws, including United States copyright law and international treaties. You will not, and will not permit or authorize third parties to: (a) reproduce, modify, translate, enhance, decompile, disassemble, reverse engineer, or create derivative works of the Threadvest Service; (b) rent, lease, or sublicense access to the Service; nor (c) circumvent or disable any security or technological features or measures of the Service.
Email Address and Electronic Communications
You do not need to register or create a user account in order to use the Threadvest Service, but we do require that you provide an email address in order to receive ETF Miner results. If you do not provide this information, we can refuse to allow you to use the Service.
By providing us with your email address, you consent to receive all required notices and information. Electronic communications may be posted on the Threadvest Service site and/or delivered to your email address that we have on file for you. Your consent to receive communications electronically is valid until you end your relationship with us.
In connection with Threadvest Offers, the Service may from time to time send you emails containing links to other sites belonging to third parties. Threadvest Offers are provided to you as a convenience. Threadvest does not endorse, warrant or guarantee the products or services available through the Threadvest Offers (or any other third-party products or services advertised on or linked from our site), whether or not sponsored. Threadvest is not an agent or broker or otherwise responsible for the activities or policies of those web sites. Threadvest does not guarantee that the loan, investment, security, plan or other service terms, rates or rewards offered by any particular advertiser or other third party are actually the terms that may be offered to you if you pursue the offer or that they are the best terms or lowest rates available in the market. Information in the Threadvest Offers is provided by third parties, and any offer is subject to the third parties’ review of your information. Threadvest may receive compensation from third parties, which may impact the placement and availability of the Threadvest Offers.
No Investment Recommendations or Professional Advice
Threadvest is not a broker-dealer and is not registered as such in any jurisdiction. Threadvest should be used for informational purposes only and is not investment advice. Threadvest, and its employees and agents are not investment advisors. If you make investment decisions in reliance on information you receive in connection with the Service, you do so at your own risk and Threadvest, its employees, and its agents will not be liable for any losses that you may sustain. You should not make any investment decision without first consulting your personal financial advisor and conducting your own research and due diligence, including carefully reviewing the prospectuses and other public filings of the issuer. To the maximum extent permitted by law, Threadvest disclaims any and all liability in the event any information, commentary, analysis, opinions, advice or recommendations on the Threadvest Service are inaccurate, incomplete or unreliable or result in any investment or other losses. Nothing on the Threadvest Service should be construed as an offer to sell, a solicitation of an offer to buy, or a recommendation for any security by Threadvest or any third party. You alone are solely responsible for determining whether any investment, security or strategy, or any other product or service, is appropriate or suitable for you based on your investment objectives and personal and financial situation.
ETF and Securities Disclaimer
You acknowledge that an investment in any security, including an ETF, is subject to a number of risks and that discussions of any security published on the Threadvest Service will not contain a list or description of relevant risk factors.
Access to the Service; Modifications to the Service
We do not provide you with the equipment to access the Threadvest Service. You are responsible for all fees charged by third parties to access the Threadvest Service (e.g., charges by internet service providers). We reserve the right to modify or discontinue, temporarily or permanently, all or a part of the Threadvest Service without notice. We will not be liable to you or to any third party for any modification, suspension, or discontinuance of the Service.
When using the Service, you must comply with all applicable laws, including without limitation, the rules and regulations of the U.S. Securities and Exchange Commission and the national or other securities exchanges, including rules against making false or misleading statements to manipulate the price of a security.
You will not, and will not permit anyone else to:
- Store, copy, modify, distribute, or resell any of the information; audio, visual, and audiovisual works; or other content made available on the Threadvest Service website (“Threadvest Content”) or compile or collect any Threadvest Content as part of a database or other work;
- Use any automated tool (e.g., robots, spiders) to use the Threadvest Service or store, copy, modify, distribute, or resell any Threadvest Content;
- Rent, lease, or sublicense your access to the Threadvest Service to another person;
- Use the Service or Threadvest Content for any purpose except for your own personal use;
- Circumvent or disable any digital rights management, usage rules, or other security features of the Service;
- Use the Service in a manner that threatens the integrity, performance, or availability of the Service; or
- Remove, alter, or obscure any proprietary notices (including copyright notices) on any portion of the Threadvest Service or Threadvest Content.
Threadvest does not actively monitor your Submissions to the Threadvest Service. However, in our efforts to promote good citizenship within the Threadvest community, if Threadvest becomes aware of inappropriate use of the Service, Threadvest shall be entitled to respond in any way that we deem appropriate in our sole discretion. You acknowledge that Threadvest may report to government authorities any actions that may be considered illegal, as well as any reports it receives of such conduct. When requested, Threadvest may cooperate with government authorities in any investigation of alleged illegal activity.
System Use Policies
When using the Threadvest Service, you agree not to:
- Use Threadvest’s facilities, services or resources (including the Service) in a manner which violates any applicable laws or regulations;
- Impersonate any person, or falsely state or otherwise misrepresent your affiliation with a person or entity;
- Use the Service in furtherance of business activities;
- Use Threadvest’s facilities, services or resources in a manner that interferes with or disrupts other network users, services or equipment. Such interference or disruption includes, but is not limited to: (i) propagation of computer worms or viruses, (ii) use of the network to make unauthorized entry to other computational, information or communications devices or resources, or (iii) use of automated processes to interact with the Service, such as scripts to harvest data. This includes unauthorized security probing activities or other attempts to evaluate the security integrity of a network or host system without permission.
Threadvest reserves the right to investigate and take legal action against anyone who, in our sole discretion, violates the restrictions set forth in this Agreement, including without limitation terminating your access to the Service.
Threadvest respects the intellectual property rights of others, and asks you to do the same. It is the policy of Threadvest to terminate the access privileges of those who repeatedly infringe the copyright rights of others. If you believe that your work has been posted on the Threadvest Service in a way that constitutes copyright infringement, please contact Threadvest at the address below and provide the following information:
- An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright interest;
- A description of the copyrighted work that you claim has been infringed, and identification of the URL or other specific location on the Threadvest Service where the material that you claim is infringing is located;
- Your address, telephone number, and email address;
- A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and
- A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf.
Threadvest’s designated agent for notice of copyright infringement can be reached at:
Attention: Marko Dedovic, Copyright Compliance Officer
225 East 57th St., Suite 15-K
New York, NY 10022
Threadvest may provide you with a mechanism to provide feedback, suggestions and ideas, if you choose, about the Service (“Feedback”). You agree that Threadvest may, in its sole discretion, use the Feedback you provide to Threadvest in any way, including in future modifications to the Service. You hereby grant Threadvest a perpetual, worldwide, fully transferable, irrevocable, royalty free license to use, reproduce, modify, create derivative works from, distribute and display the Feedback in any manner for any purpose.
Disclaimer of Warranties
YOUR USE OF THE SERVICE AND THREADVEST CONTENT IS AT YOUR SOLE RISK. THE SERVICE AND THREADVEST CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. THREADVEST EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT. WE DO NOT GUARANTEE THE ACCURACY, COMPLETENESS, OR USEFULNESS OF THE SERVICE AND THREADVEST CONTENT, AND YOU RELY ON THE SERVICE AND THREADVEST CONTENT AT YOUR OWN RISK. ANY MATERIAL OBTAINED THROUGH THE SERVICE IS OBTAINED AT YOUR OWN DISCRETION AND RISK AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF ANY MATERIAL THROUGH THE SERVICE. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM THREADVEST OR THROUGH OR FROM THE THREADVEST SERVICE WILL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THIS AGREEMENT. SOME STATES MAY PROHIBIT A DISCLAIMER OF WARRANTIES AND YOU MAY HAVE OTHER RIGHTS THAT VARY FROM STATE TO STATE.
Limitation of Liability
THREADVEST WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES (EVEN IF THREADVEST HAS BEEN ADVISED OF THE POSSIBILITY OF THESE DAMAGES), RESULTING FROM YOUR USE OF THE SERVICE AND THREADVEST CONTENT. UNDER NO CIRCUMSTANCES WILL THREADVEST’S TOTAL LIABILITY OF ALL KINDS ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICE OR THREADVEST CONTENT (INCLUDING BUT NOT LIMITED TO WARRANTY CLAIMS), REGARDLESS OF THE FORUM AND REGARDLESS OF WHETHER ANY ACTION OR CLAIM IS BASED ON CONTRACT, TORT, OR OTHERWISE, EXCEED THE TOTAL AMOUNT PAID BY YOU TO THREADVEST FOR USE OF THE SERVICE AND THREADVEST CONTENT. BECAUSE SOME STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU.
You will indemnify and hold Threadvest, and its subsidiaries, affiliates, officers, agents, and employees, harmless from any costs, damages, expenses, and liability caused by your use of the Service or Threadvest Content, your violation of this Agreement, or your violation of any rights of a third party through use of the Service or Threadvest Content.
Links and Third Party Content
The Threadvest Service may contain links to third party products, services, and websites. We exercise no control over the third party products, services, and websites and we are not responsible for their performance, do not endorse them, and are not responsible or liable for any content, advertising, or other materials available through the third party products, services, and websites. We are not be responsible or liable, directly or indirectly, for any damage or loss caused to you by your use of or reliance on any goods or services available through the third party products, services, and websites. Additional information regarding Dow Jones data can be found by clicking on the link, https://us.spindices.com/terms-of-use/.
Updates to the Service and this Agreement
We may occasionally update the Service and this Agreement. When we do, we will revise the “last updated” date on this Agreement. You should check the Threadvest Service and this Agreement frequently to see recent changes. By continuing to use the Threadvest Service, you consent to any updates to the Service and this Agreement. This version of this Agreement supersedes all earlier versions.
Intellectual Property Rights
Threadvest may have patents, patent applications, trademarks, copyrights, or other intellectual property rights covering subject matter in the Service. Except as expressly provided in this Agreement, the furnishing of the Service to you does not give you any license to these patents, trademarks, copyrights, or other intellectual property. Any rights not expressly granted herein are reserved.
This Agreement is governed by the laws of the State of New York, excluding conflicts of law principles. Any legal actions against us must be commenced in the State of New York within one year after the claim arose. You consent to the exclusive jurisdiction of the state and federal courts located in New York County, New York.
What We Do With Your Personal Information
We use your Personal Information to deliver our Services to you, operate our business, and help make our Services useful, more intelligent, and work better for you.
Types of Personal Information We Collect. When you access or use the Threadvest Service, we may collect:
- Your email address;
- Information you provide the ETF Miner regarding your interests, investment priorities, and investment purposes; and
- Other information you may provide to us.
For example, when you answer questions to tailor your ETF Miner results to your interests and preferences, we collect your answers, as well as the email address you provide so that we can send you your results. Also, if you communicate with us to provide feedback about the Threadvest Service, we collect any Personal Information you provide in your communications to us.
Automatic Collection of Certain Threadvest Usage Data. We may automatically collect certain usage information when you access our Services (“Usage Data”), such as IP addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. For example, we collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services.
Our Services may change over time and we may introduce new features that may collect new or different types of information.
How We Use Your Personal Information. Unless prohibited by law, regulation, or a contractual obligation, we may use your Personal Information, including your Personal Information, for the following purposes:
- To Provide the Threadvest Service. For instance, if you provide the ETF Miner information about your interests, investment priorities, and investment purposes, we will use that information to provide you with ETFs that could meet your needs .
- Communications. We may send emails to the email address you provide to us for informational and operational purposes and to respond to communications from you.
- Marketing. We may use information about you for marketing purposes, such as providing advertising on the Threadvest Service and sending you information we think may be useful or relevant to you. You may opt out of email marketing by using the unsubscribe link in a marketing email.
- Internal and Service-Related Usage. We may use Personal Information for internal and service-related purposes. We may use and retain any data we collect to provide and improve any of our services.
- Aggregate Data. We may anonymize, deidentify, or aggregate data collected through the Threadvest Service. This data is not Personal Information, and we may use and disclose such data for any purpose.
How We Share Your Personal Information. From time to time, we may need to share your Personal Information with others:
- Third-Party Service Providers. We may share your Personal Information and Usage Data with third party-service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics.
- Response to Subpoenas and Other Legal Requests. We may share your Personal Information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
- Protection of Threadvest and Others. We may share Personal Information and Usage Data when we believe it is appropriate to enforce or apply our Terms of Service and other agreements, or to protect the rights, property, or safety of Threadvest, our users, or others.
- Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your Personal Information. If so, you will be asked if you would like to stop receiving promotional information following any change of control.
- With Your Permission. We may also disclose your personal information with your permission.
Cookies and Similar Tracking Technology
In accordance with applicable law, Threadvest and our service providers may use commonly-used tools to recognize your visit and track your interactions with the Threadvest Service, such as cookies, web beacons, pixels, local shared objects, and similar technologies (collectively, “Cookies”). Sometimes this tracking is necessary in order for us to provide you Services you requested. Other times, we combine Usage Data collected from Cookies with that of other customers to improve your and other customers’ experiences. You have control over some of the Usage Data we collect from Cookies and how we use it. Information on changing your browser settings to opt out of Cookies can be found in your browser settings.
Threadvest may use advertising networks and other third parties to display advertising on our website or to manage our advertising on other sites. Our third party partners may place Cookies on our Services and unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests, and to determine the effectiveness of such advertisements.
You may be able to opt out of receiving personalized advertisements on this browser or device from advertisers, or other advertising networks who are members of the Network Advertising Initiative (“NAI”) or who subscribe to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those sites are here:
Browser Opt-Out: http://www.networkadvertising.org/choices/
Browser Opt-Out: http://www.aboutads.info/choices/
You may be able to change browser settings to block and delete cookies when you access the Threadvest Service through a web browser. However, if you do that, the Service may not work properly. When you opt out of personalized advertising, you may continue to see online advertising on the Service and/or our ads on other websites and online services. The Threadvest Service does not respond to browser “Do Not Track” signals.
In accordance with and as permitted by applicable law and regulations, we will retain your Personal Information as long as necessary to serve you or as otherwise needed to operate our business. We will retain and use your Personal Information as required by applicable law and Threadvest’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.
Security of Your Personal Information
Intentional Data Transfers
In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your Personal Information, process and store it outside your country of residence to wherever we or our third party service providers operate.
Collection and Use of Children’s Personal Information
We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of the Threadvest Service is directed to children under the age of 18. If you learn that your child has provided us with personal information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any personal information from children under 18, we will promptly take steps to delete such information.
Your California Privacy Rights
We do not share your Personal Information with third parties for their marketing purposes without your consent.
How to Contact Us
Via Direct Mail. If you prefer to communicate by mail, we can be reached at:
225 East 57th St., Suite 15-K
New York, NY 10022
If you have any questions or concerns about the Threadvest Service or this Agreement, please send us a thorough description by email to email@example.com.