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Privacy Policy.

*Last Modified: February 11, 2022

Introduction

American Stock Transfer & Trust Company, LLC and its affiliates (collectively, “AST”, “we”, “us” or the “Company”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (this “Policy”). Your privacy is important to AST and we go to great lengths to protect it.

This Policy describes the types of personal information we may collect from you or that you may provide to us anytime you are in contact with AST, including via any online or mobile site or application owned and controlled by AST (the “Websites”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it.

Children Under the Age of 13

AST’s services and the Websites are not intended for children under 13 years of age. No one under age 13 may provide any personal information to AST, and AST will not knowingly collect personal information from children under 13. If you are under 13, do not provide any information about yourself to us (including through our Websites by using any of its features or registering on our Websites), including, without limitation, your name, address, social security number or tax identification number, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

Information We Collect About You and How We Collect It

Personal information means any information that is about you or which can help identify you.  We may collect several types of personal information about you, including information:

  • By which you may be personally identified, such as name, mailing address, e-mail address, telephone, fax or mobile number, social security number or tax identification number, account number, securities or other asset ownership information; and
  • About your internet connection, the equipment you use to access our Websites and usage details.

We may collect this information in a number of different ways.  We collect this information directly from you when you provide it to us, automatically as you navigate through the Websites, and from third parties in the performance of our services.

We do not collect or process any personal information in certain special categories, such as data that discloses racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

Information You Provide to Us.

We collect the personal information that you choose to provide to us, including through any letter, telephone, email or any other means of electronic or personal communication.  Depending on the reason you are contacting us, the personal information we collect may include your name, date of birth, social security number or tax identification number, address, phone number, email address, employment details, and banking information.

The information we collect on or through the Websites may include:

  • Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Websites.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Websites and of the execution of your instructions. You may be required to provide financial information before performing certain transactions through our Websites.
  • Your search queries on the Websites.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites; and
  • Information about your computer or other device you use to visit our Websites and your internet connection, including your IP address, operating system, browser type and version, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.
  • Web Beacons. Pages of our Websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages band for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Web Analytic Tools. Our Websites may use Google Analytics or similar web analytics tools that help website owners analyze the traffic to their websites.  By using Google Analytics, the Company may be able to view a variety of reports about how users interact with the Websites, which can be used to improve your user experience and the overall quality of the Websites.

Information We Collect from Third Parties.

We may also collect your personal information from third parties in the course of performing our services.  For example, companies that engage us for our services may provide us with information relating to their shareholders, such as name, date of birth, social security number or tax identification number, address, phone number, employment details, and other personal information.  

How We Use Your Personal Information

We use personal information that we collect about you or that you provide to us, including any personal information:

  • To respond to your inquiries and fulfill your requests.
  • To provide services to you and to our issuer clients.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To fulfill any other purpose for which you provide it.
  • To present our Websites and its contents to you.
  • To inform you about information regarding the Websites, products or services for which you apply or may be interested in applying for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information.
  • To verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of account and personal information.
  • To allow you to participate in interactive features on our Websites, including surveys and other forms of market research.
  • To help us to improve our Websites and to deliver a better and more useful experience to our customers and to understand which parts of our Websites, products, and services are of most interest.
  • For risk control, fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements.
  • To deliver marketing communications that we believe may be of interest to you, including ads or offers tailored to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To comply with a legal obligation or to carry out a legitimate interest that we or a third party may have.
  • In any other way we may describe when you provide the information.

When We Share Your Personal Information

Please see the Privacy Notice for information on how personal information may be shared with third parties.  Additionally, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

How Long We Store Your Personal Information

We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your personal information, we will consider (a) the amount, nature, and sensitivity of such information, (b) the potential risk of harm from unauthorized use or disclosure of such information, (c) the purposes for which we process such information and whether we can achieve those purposes through other means, and (d) the applicable legal, regulatory, accounting or reporting requirements.

Upon expiration of the applicable retention period, we will securely destroy your personal information in accordance with applicable law and regulation.

How You Can Access and Update Your Personal Information
You may request a copy of the personal information we hold about you by contacting us.  You may also review and change your personal information by logging into the Websites and visiting your account profile page. 

Data Security

We have implemented measures designed to secure, to the best of our ability, your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

California Residents Disclosure

This section only applies to individuals who are residents of California under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (together “California Laws”).

a. Personal Information Collected

Below is a summary of the Personal Information we collect as a Business in the preceding 12 months, the reason we collect your Personal Information, where we obtain the Personal Information we collect about you, and the third parties that we share your Personal Information categorized as outlined in California Law.

b. California Residents Privacy Rights

Under California Laws, California residents have the following rights (“Rights”) listed below. Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of the business’s systems of networks.

  • Disclosure & Access Rights: California consumers have the right to request in writing from a business, (i) a list of the categories of personal information, such as name, address, e–mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, California residents have the right to request that we disclose to them (i) the categories of personal information we have collected about them, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual.
  • Deletion Rights: California consumers have the right to have their personal information deleted, unless the personal information is necessary for the business or service provider to:
    • complete a transaction for which the personal information was collected, provide a good or service requested by the consumer or otherwise perform a contract between the business and the consumer;
    • detect security incidents;
    • protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible);
    • debug to identify and repair functionality errors;
    • exercise or ensure the right of another to exercise free speech or another legal right;
    • comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant;
    • engage in research in the public interest (if the consumer has provided informed consent);
    • to enable solely internal uses aligned with the consumer’s expectations given their relationship with the business;
    • comply with a legal obligation;
    • otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided it.
  • Do Not Sell: Californian consumers have the right to opt-out of having their personal information sold. We do not sell personal information.

Californians can exercise their privacy rights by contacting us at privacy @astfinancial.com.

Response Time.  We will handle request under Applicable Law in California. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 45 days following receipt at the e–mail or mailing address stated above. Please note that we are only required to respond to each customer twice per 12 month period.

c. California Do Not Track Disclosures

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.

Nevada Residents Do Not Sell Disclosure

Nevada law entitles you to request that we refrain from sale of your personal information. We do not sell your personal information as defined by California law. If you have a question or concern, please contact us at [email protected] for more information.  

European Residents Disclosure

Residents of the European Economic Area (“EEA”), United Kingdom, and Switzerland have the following data protection rights:

  • Data Subject Access Rights: If residents of the EEA, United Kingdom, and Switzerland wish to access, correct, update or request deletion of their personal information, they can do so at any time.
  • Right to Object: Residents of the EEA, United Kingdom, and Switzerland can object to processing of their personal information, ask to restrict processing of their personal information or request portability of their personal information.
  • Consent Revocation: If personal information was collected with consent, then residents of the EEA, United Kingdom, and Switzerland can withdraw their consent at any time.  Withdrawing consent will not affect the lawfulness of any processing conducted prior to your withdrawal, nor will it affect processing of personal information conducted in reliance on lawful processing grounds other than consent.
  • Complaints: Residents of the EEA, United Kingdom, and Switzerland have the right to complain to a data protection authority about the collection and use of their personal information.  For more information, please contact your local data protection authority.

Please note that you should direct any requests related to the data protection rights described above to the AST Client who holds the relevant AST account. As a data processor of any personal information stored and processed on the Services, AST will not be able to respond directly to such requests and will refer any such requests to the relevant Client. If you have additional questions, please send an email to [email protected].

Changes to the Policy

It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Websites. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Websites and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us by email at privacy @astfinancial.com.

Introduction and scope of policy

This Online and Mobile Privacy Policy (“Policy”) applies to your interaction with Equiniti Trust Company, LLC, EQ, Shareowner Services, or any of their affiliates (collectively, “EQ,” “we,” “us,” “our”), at any online or mobile site or application that we own and control (“Site”), unless a different online and/or mobile policy is posted at a particular site, or is made available to you and by its terms supplants this Policy. Other privacy policies may also apply in addition to the terms of this Policy. This Policy also explains certain data use and data protection functionalities and practices of our email, online ads, such as banner ads, on third-party sites. Please note that where we have another type of presence on a site owned by a third party, such as a page or handle on a social media site, that third party’s privacy policy and terms of use, rather than this Policy, will govern, unless specifically stated otherwise.

Agreement to policy

By using a Site or interacting with an EQ page or account on a third-party site, you consent to this Policy, including your consent to our use and disclosure of information about you in the manner described in this Policy.

Gathering, using and sharing information

Types of Information

You may interact with us in a variety of ways online, including through a mobile device, if that functionality is offered. We may offer sites or applications that permit browsing and do not require registration. We may also offer the ability to access your accounts online. Information that we may collect about you through online interaction includes information that you input, such as your name, address, email address, other contact information; data resulting from your activity, such as transaction information; and location information. We may also gather additional information such as the type of device and browser you are using, the IP address of your device, information about your device’s operating system, and additional information associated with your device. We may also gather information collected through cookies, tags, and other technologies, as described further below.

About “Cookies”

Cookies are pieces of data stored on your device. Browser cookies are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server. Mobile applications may also use cookies.

We use cookies and information gathered through their use to make your experience with EQ and certain other sites richer and more personalized based on the products, services, or other interaction you have with us and other sites.

Other parties that may collect information about your web browsing behavior when you use our Site are generally limited to service providers who may only use any information collected to provide services and marketing for us and not to provide services or advertising for any other party. Note, however, that we may also provide certain widgets or tools on our sites, such as tools that allow web surfers to easily share information on another platform, such as a social media platform. At other times, information from a third party may be embedded on our site, such as a map or information streaming from another site, including communications streaming from a third-party social media platform. These widgets, tools, and informational items often function through the use of third-party cookies utilized by the third-party site, such as the social media platform. You may wish to review information at third-party sites, such as social media platforms where you have an account, to determine how these third parties treat data that they obtain through the use of cookies.

We also use cookies for purposes such as maintaining continuity during an online session; gathering data about the use of our site; monitoring online promotions; and anti-fraud and information security purposes.

Do You Have to Accept Cookies?

You may be able to set your browser to reject browser cookies. However, if you choose to reject cookies, you may not be able to access your accounts online with EQ. Therefore, if you set your browser options to disallow cookies, you may limit the functionality we can provide when you visit our Site. The latest versions of internet browsers provide cookie management tools, such as the ability to delete or reject cookies. We recommend that you refer to information supplied by browser providers for more specific information, including on how to use these tools.

Additional Cookies

Cookies is a term also used to describe other locally stored objects, such as cookies stored in an Adobe folder on your device. These cookies will not be deleted when you clear cookies from your browser. We may use this technology for purposes such as information security and fraud prevention. We do not use this technology for online behavioral advertising purposes. Please refer to information provided by Adobe for information on how to disable and control Flash objects. If you choose those options, you may limit the functionality we can provide when you visit our Site.

Additional Technologies

We may also use additional technologies such as pixel tags, web beacons, and clear GIFs, and may permit our third-party service providers to use these technologies. We may use these technologies for purposes such as measuring the effectiveness of our communications and determining viewing and response rates.

Using Information

In addition to the uses described above, we use information for purposes as allowed by law such as: servicing; communicating with you; improving our Site, products, or services; legal compliance; risk control; information security; anti-fraud purposes; marketing or personalizing the presentation of our products and services to you; tracking website usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our sites; and we may also use read-receipt notifications in our email communications.

Sharing

We may share information with service providers or affiliates with whom we work, such as data processors and companies that help us provide products and services to you. When permitted or required by law, we may share information with additional third parties for purposes including response to legal process.

If you are a resident of the State of California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”), EQ hereby advises you of the following:

  1. We collect identifying information about you, including your name, address, Tax Identification Number (Social Security Number), and possibly your telephone number and information about your computer usage, including your IP address.
  2. We collect this information in order to enable us to provide services to you. We do not sell your information to any third parties.
  3. This information may be shared with tax authorities, print and mail vendors, entities who perform services directly related to our services as the registrar and transfer agent for the securities you own, and the issuers whose securities you may own.
  4. You have the right to contact us and request copies of the information we hold about you, and to request that this information, if inaccurate, be corrected. We can be reached through US Mail, our telephone numbers associated with the securities you hold, or by sending a request through the Contact Us link at shareowneronline.com.
  5. While the CCPA affords you the right to request that your information be deleted from our systems, because this information is needed to perform the services we carry out on behalf of you as a shareholder and the issuers whose securities you may own, we are unable to delete your data if requested.

If you have any questions about your rights under the CCPA, please contact us and we will endeavor to assist you.

EQ Data Protection Officer
48 Wall Street
23rd Floor
New York, NY 10005
[email protected]

Children’s privacy

From our web pages, we do not knowingly collect personal information from individuals under the age of 13 without obtaining verifiable consent from their parents.

For more information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov

Policy updates and effective date

If we make updates to this Policy, we will update the Policy with the changes and revise the “Last updated” posted at the bottom of this Policy. Any updates to the Policy become effective when we post the updates on the Site. Your use of the Site following the update to the Policy means that you accept the updated Policy.

Last Updated: September 1, 2022