Date of most recent update: December 4, 2019
1. INTRODUCTION AND SCOPE OF POLICY
2. AGREEMENT TO POLICY
By using a Site or interacting with a Shareowner Services 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.
3. 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.
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:
- 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.
- We collect this information in order to enable us to provide services to you. We do not sell your information to any third parties.
- 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.
- 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.
- 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.
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 Shareowner Services. 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.
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.
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.
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.
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.
4. 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:
5. POLICY UPDATES AND EFFECTIVE DATE
If we make updates to this Policy, we will update the Policy with the changes and revise the “date of most recent update” posted at the top 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.
6. GENERAL DATA PROTECTION REGULATION (GDPR)
Effective May 25, 2018, the European Union adopted a regulation known as the General Data Protection Regulation (GDPR).
As a resident of the European Union, you are protected by the provisions of the GDPR. As an entity known as a Data Controller, the issuer of stock is subject to provisions of the GDPR regarding your personal data and information.
Please take time to review the following Privacy Notice, which sets out your rights under the GDPR. If you have any questions, please contact:
EQ Data Protection Officer
90 Park Avenue
25th Floor New York