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Broadridge Financial Solutions, Inc., including its subsidiaries and affiliates (collectively, “Broadridge”), is committed to respecting privacy. Our Global Privacy Program is designed to help ensure that we handle personal information appropriately. The statements below provide information about how we collect and use personal information from our clients, service providers, and from individuals who interact with us directly, including visitors to www.broadridge.com and other Broadridge websites, mobile applications, or hosted websites that link to this Privacy Statement. If you have any additional questions about the privacy of your personal information, please contact the Broadridge Privacy Office via email at email@example.com.
This Privacy Statement describes the practices that Broadridge will follow with respect to the personal information it collects from our clients, service providers and from individuals who interact with us directly, including visitors to www.broadridge.com and other Broadridge websites, mobile applications, or hosted websites that link to this Privacy Statement. With respect to consumer data, Broadridge generally operates as a service provider to our clients, including banks, brokers, mutual funds, corporations and other business entities. As a service provider, we collect and use personal information as authorized by our contracts with our clients. If we have collected or received your personal information in our capacity as a service provider to a Broadridge client with which you have a financial account or relationship, that company can assist you with requests related to exercising your privacy rights, as Broadridge cannot fulfill these requests directly. We suggest you reach out to such company to learn more about its privacy practices and make requests to exercise your rights. Broadridge supports our clients as needed to help them respond to such requests.
Understanding Personal Information
“Personal information” is information that can be used to identify, locate or contact an individual. We collect the following types of personal information:
Client Confidential Information
Broadridge collects and processes consumer personal information as a service provider to our clients. All such consumer information we process is considered Confidential Information of our clients, and we only use and disclose this information to provide services to our clients and as instructed by our clients.
In some cases, we operate or host websites owned by our clients. On behalf of our clients, we may collect personal information (including sensitive personal information) when users access their accounts online or conduct transactions. All of the information collected via these hosted sites is considered Confidential Information of our clients. We also receive personal information directly from our clients for processing, which is also Confidential Information of our clients.
Our contracts with our clients govern the processing of this Confidential Information, and the clients’ privacy statements provide information about their privacy practices. If we have collected or received your personal information in our capacity as a service provider to a Broadridge client with which you have a financial account or relationship, that company can assist you with requests related to exercising your privacy rights, as Broadridge cannot fulfill these requests directly. We suggest you reach out to such company to learn more about its privacy practices and make requests to exercise your rights. Broadridge supports our clients as needed to help them respond to such requests.
How Broadridge Collects, Uses, and Discloses Personal Information
We may also collect information about you from third party data suppliers who enhance our files and help us better understand our website visitors and clients, or through publicly-available social media sites, such as LinkedIn or Twitter.
If you provide personal information to us for our own use, we may use it to provide the products, services or information that you have requested and we may share it with our affiliates and service providers. We may also use your personal information for other internal business purposes, such as market research and legal compliance. We will only use or disclose your personal information when we have a legal basis to do so.
We may share any personal information, even Confidential Information, with our service providers, but the use of such personal information for their own purposes is prohibited.
Please note that we may disclose any information as required by law, when necessary for health or safety purposes, or when needed to protect our legal rights, including to law enforcement agencies and courts in the United States and other countries where we operate in accordance with applicable laws. For example, we may disclose information about you in response to a subpoena. We may also disclose information about you in connection with the transfer of assets of our business.
Cross-Border Transfers of Personal Information
Broadridge is headquartered in the United States and has offices, affiliates and service providers around the world. Your personal information may be transferred to other countries, which may not have similar privacy or data protection laws to those where you live. However, Broadridge will always protect your personal information, no matter where it may be stored.
If you are located outside the United States, we generally use approved Standard Contractual Clauses to authorize the transfers for personal information and to demonstrate that the information remains adequately protected. Please contact us via email at firstname.lastname@example.org if you would like to learn more about our cross-border transfers.
We may offer mobile applications that allow you to access accounts, interact with us or our clients online and receive other information via your smartphone or other mobile device. All personal information collected by Broadridge via our mobile applications is protected by our client contracts and the terms of this Privacy Statement.
When you download our mobile applications, you may choose to allow us to obtain your precise location from your mobile device. We use this information to deliver personalized content to you, for our internal analytics purposes. We may provide this information to our clients pursuant to client contracts and to our service providers.
We may also offer automatic (or “push”) notifications. We will provide push notifications only to those individuals who opt-in to receive such notifications. You do not have to provide location information to Broadridge or enable push notifications to use any of our mobile applications. If you have questions about location and notification privacy, please contact your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Social Media Interactions and Interest-based Ads
Our websites may enable you to interact with us and others via social media platforms, such as Facebook, Google, Twitter, LinkedIn and Instagram. While we respect each social media platform’s privacy policies, we may collect personal information about you if you choose to use these tools.
We may display interest-based ads to you when you are using these platforms. These platforms allow us to personalize the ads that we display to you. We do not share any of your personal information with these platforms, although we may convert your personal information collected into unique numbers which can be matched by the platform with its user to allow delivery of the advertising. Although we do not provide any personal information to these platforms, they may gain insights about individuals who respond to the ads we display.
Broadridge is a business to business service provider and does not market its services to individual consumers. However, Broadridge does provide certain information by subscription and generally uses an opt-in format for choosing future e-mail communications in specified subject areas. These e-mail communications contain links to unsubscribe from future e-mail communications. Broadridge also may use the personal information you provide on Broadridge websites to contact you to respond to your inquiries or to contact your business about information relating to Broadridge’s products and services from time to time. Please email us at email@example.com if you do not want your information used for further marketing contact. Broadridge does not send Broadridge marketing communications to individuals who provide us with personal information via a website we host for a client.
Your Privacy Rights
Broadridge respects your rights to access, correct and request erasure or restriction of your personal information as required by law. This generally means that:
Depending on where you reside, you may have additional rights under applicable law. To learn more and to exercise your rights, please contact us via email at firstname.lastname@example.org. We will need to confirm your identity before we can fulfill most requests, as we need to be sure that your personal information is not disclosed to an unauthorized recipient.
Please understand that these rights are subject to some limitations, such as when we are processing or retaining data to comply with our own legal obligations.
If we have collected or received your personal information in our capacity as a service provider to a Broadridge client with which you have a financial account or relationship, that company can assist you with requests related to exercising your privacy rights, as Broadridge cannot fulfill these requests directly. We suggest you reach out to such company to learn more about its privacy practices and make requests to exercise your rights. Broadridge supports our clients as needed to help them respond to such requests.
We take reasonable steps to help prevent the loss, misuse and alteration of the information under our control. For example, we have implemented physical, logical and administrative safeguards to protect and secure the information we process and maintain. We also use encryption and firewall technologies to protect sensitive information during online transmissions.
If you have registered at a Broadridge website or a hosted website, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also remember to sign out of the registered site and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if others have access to your computer.
We will retain your personal information for as long as the information is needed for the purposes listed above and for any additional period that may be required or permitted by law, such as for business, legal, accounting, or reporting requirements or pursuant to client contract requirements.
The length of time your personal information is retained depends on the purpose(s) for which it was collected, how it is used, and the requirements to comply with applicable laws or client contracts. If you would like us to delete your personal information collected directly by Broadridge, please contact us via email at email@example.com. If we do not have a legal basis for retaining your information, we will delete it as required by applicable law. If we have collected or received your personal information in our capacity as a service provider to a Broadridge client with which you have a financial account or relationship, that company can assist you with requests related to deleting your personal information.
Changes to this Privacy Statement
From time to time, we may update this Privacy Statement to reflect new or different privacy practices. We will place a notice online when we make material changes to this Privacy Statement. Additionally, if the changes will materially affect the way we use or disclose previously-collected personal information, we will notify you about the change.
Privacy Protection Policy for Social Security Numbers
Broadridge may collect Social Security numbers in the ordinary course of certain of its businesses. Broadridge has implemented reasonable technical, physical and administrative safeguards to help protect the Social Security numbers from unlawful use and unauthorized disclosure. All Broadridge employees and service providers are required to follow these established procedures.
Broadridge sites may contain links to other sites, including those of our service providers. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other sites.
Job Applicants and Human Resources (HR) Data
If you have applied for employment with Broadridge, the personal information submitted with your job application will be used only for recruitment and other customary human resources purposes Prospective, current and former employees and others whose data are processed in connection with our human resources activities may contact the Broadridge Privacy Office via email at .firstname.lastname@example.org or Human Resources Department to get information about Broadridge’s Human Resources privacy practices.
When you visit our website or use our mobile applications, we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser tracking analysis tools, server logs and web beacons. We do not, however, use tracking or cookie technology on pages of our websites that provide “Notice and Access” hosting services to clients.
When you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. You have choices about these cookies.
To learn more about the cookies we place and to exercise your choices, please visit our Cookie Management Tool.
Click on the different category headings to find out more and change our default settings according to your preference. You cannot opt-out of our Strictly Necessary Cookies as they are deployed in order to ensure the proper functioning of our website (such as prompting the cookie banner and remembering your settings, to log into your account, to redirect you when you log out, etc.). However, you can opt-out of our use of Performance and Targeting Cookies.
Other Data Collection Technologies
We may also use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. We use Flash cookies for security purposes and to help remember settings and preferences. We do not use Flash cookies or similar technologies for behavioral or interest-based advertising purposes. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. To manage Adobe Flash cookies, please visit Adobe’s website at www.adobe.com.
These technologies also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about the privacy settings that may be available.
In connection with marketing efforts, we may use pixel tags and web beacons, which are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure responses to our communications and improve our websites and promotions. Information collected using these technologies in our e-mails may be associated with the recipient’s e-mail address.
For example, we may collect information from the device you use to access our website, including your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you visited our websites and the website you visit after you leave our site.
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to personal information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your personal information.
On some of our sites, such as www.broadridge.com and certain annual meeting websites (e.g., the Virtual Shareholder Meeting, which may be customized for our client), and mobile applications, Broadridge directly or through third parties uses web analytics tools to provide Broadridge or its clients with information about the use of these websites.
Other Third Party Relationships
Broadridge also uses web analytics tools provided by Adobe. These tools also provide reporting and analytics functions that help us understand how visitors engage with our websites. To learn more about the Adobe analytics products, please visit http://www.adobe.com/privacy/marketing-cloud.html.
Broadridge provides a third party, Demandbase, Inc., with the IP addresses recorded by Broadridge’s server logs of visitors to Broadridge’s sites. Demandbase’s web analytics identify information about visitors to Broadridge’s sites, including, without limitation, industry, size, location and revenue, based on Demandbase’s database of company IP addresses.
You may refuse the use of these companies’ cookies by opting-out of our collection of data via Performance and Targeting Cookies, using our Cookie Management Tool.
Do Not Track
Although our websites currently do not have a mechanism to recognize web browser Do Not Track signals, visitors to our websites may manage their cookie preferences in their browser settings. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/.
Broadridge Corporate Issuer Solutions, a registered transfer agent, follows Broadridge’s information security program and practices to address the risk that client information acquired in the course of its business is disclosed without authorization, misused, altered, destroyed, or otherwise compromised. As part of this information security program, Corporate Issuer Solutions has implemented numerous physical, electronic, and procedural safeguards to prevent such disclosure, misuse, alteration, destruction, or compromise, including limiting access to information to necessary employees and the encryption of sensitive website transmissions using Secure Sockets Layer (SSL) protection, and has implemented appropriate measures to oversee its service providers’ compliance with the program. Corporate Issuer Solutions also has adopted protocols for the proper disposal of any consumer report information acquired in the course of its business.
Corporate Issuer Solutions may maintain some or all of the following personal information with respect to individual shareholders:
Corporate Issuer Solutions maintains its records of securities and shareholders as an agent for the issuer of the security, and, accordingly, will provide the above-referenced information to the issuer or its designees. Corporate Issuer Solutions does not provide the aforementioned information about current or former shareholders to any third party except to provide the services or as permitted by law. Corporate Issuer Solutions will provide personal information:
Broadridge is providing this additional information, as required by the EU General Data Protection Regulation, for the benefit of individuals in the European Economic Area (EEA), United Kingdom and Switzerland, to explain our practices with regard to European Economic Area (EEA), United Kingdom and Swiss personal data.
1. Information about Broadridge
Broadridge Financial Solutions, Inc.
Attn: General Counsel
5 Dakota Drive
Lake Success, New York 11042
2. The Purposes and Legal Basis for Processing, including Legitimate Interests
We only process personal information when we have a legal basis for the processing, such as:
We may also process your personal information for our legitimate interests, provided that such processing shall not outweigh your rights and freedoms. In particular, we may process your personal information as needed to:
3. The Purpose for which we Process your Personal Information
We process your personal information for the legitimate interests we have referred to above and for the following purposes:
4. Your Rights
You always have the right to object to our marketing communications. To opt-out of emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. To revoke permissions that you may have given to send text messages, text STOP in response to any message.
Broadridge also respects the rights of EEA, United Kingdom and Swiss residents to access, correct and request erasure or restriction of their personal information as required by law. This means:
If your personal information was provided to us by a client which is a company with whom you have an account or relationship, you should reach out to such company to learn more about its privacy practices and how to exercise your rights.
If Broadridge has collected personal information directly from you, to exercise these rights, please contact us via email at email@example.com or write us at the address above, and a member of our Privacy Office will assist you. Please understand that we may need to verify your identity before we can process your request.
If you believe that we have processed your personal information in violation of applicable law, you may file a complaint with the Broadridge Chief Privacy Officer at firstname.lastname@example.org or with a supervisory authority.
5. International Transfers
Your personal information may be transferred to, stored at or processed in the United States and other countries which may not have equivalent privacy or data protection laws. However, we will always protect your information as described in this Privacy Statement, no matter where it is stored.
We generally use approved Standard Contractual Clauses to assure that personal information is adequately protected when it is transferred out of the EEA, the United Kingdom or Switzerland to countries without an adequate level of data protection, but we may also make transfers to recipients using other approved data transfer mechanisms.
We process client data as needed to provide services to our clients, in accordance with our contracts. For example, our clients use our services to communicate with, manage and build relationships with their customers, investors or shareholders. We use information about the individuals as needed to provide these services and otherwise support our clients’ account management and compliance functions.
As permitted by our client contracts, we rely on some third parties to provide services to us, such as data hosting, that may have access to client data. Broadridge has contracts with these third parties to assure that client data is protected at all times with appropriate privacy and security controls.
6. Data Retention
We will retain your personal information for as long as the information is needed for the purposes set forth above and for any additional period that may be required or permitted by law. If we have collected or received your personal information in our capacity as a service provider to a Broadridge client with which you have a financial account or relationship, that company can assist you with requests related to exercising your privacy rights, as Broadridge cannot fulfill these requests directly. We suggest you reach out to such company to learn more about its privacy practices and make requests to exercise your rights. Unless we are required by law to retain your information, where we are: (i) a data controller we will delete your personal information upon your request; and (ii) a data processor, we will delete personal information pursuant to the instruction of our client, the data controller. If Broadridge has collected personal information from you directly, and you want to make a request to delete such information, contact us via email at email@example.com.
7. Disclosure of Your Personal Information
Other than as set out below, your information will not be sold, shared or provided to any third party:
While we don’t sell, share or provide your personal information other than as set forth in this Privacy Statement, our website includes a mechanism to manage data shared with third parties via our cookies via our Cookie Management Platform.
The California Consumer Privacy Act (“CCPA”) provides California residents with specific privacy rights, including the right to receive a privacy notice, the right to know what information we have collected about such resident during the past 12 months, and the right to know what categories of personal information we have shared with third parties.
If we have collected or received your personal information in our capacity as a service provider to a Broadridge client with which you have a financial account or relationship, that company can assist you with requests related to exercising your privacy rights, as Broadridge cannot fulfill these requests directly. We suggest you reach out to such company to learn more about its privacy practices and make requests to exercise your rights. These companies can authenticate you and provide information about the rights that you may have under CCPA or other applicable laws.
For website visitors, our websites do store cookies on your browser to collect information. The information collected might relate to you, your preferences or your device, and is mostly used to make the site work as you expect it to and to provide a more personalized web experience. You have choices about these cookies. To exercise your rights to opt-out of our collection of data via Performance and Targeting Cookies, please use our Cookie Management Tool.
Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can always reach us via email at firstname.lastname@example.org. You can also reach us via mail at the postal address provided above.
Broadridge Financial Solutions, Inc.
Attn: Chief Privacy Officer
5 Dakota Drive
Lake Success, New York 11042
This Privacy Statement was last updated November 9, 2021.