We understand how important your personal data is and are committed to protecting and respecting your privacy. EQ strives to make your online and mobile experiences satisfying and safe.
‘Personal Data’ means any information relating to or which identifies you. This can include items such as your name, address, phone number, identification numbers (such as an account number or your social security number), location data or online identifiers. Personal data can be held electronically or in certain paper records.
At all times we comply with applicable laws and regulations governing the confidentiality and security of information we receive and maintain.
1. Who we are
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”), our online or mobile sites or applications, (“Site” or “Sites”) unless a different online and/or mobile policy is posted at a particular site and by its terms supplants this Policy.
IMPORTANT
This Privacy Notice relates only to the webpages that you log onto as part of our portal services and relates to your online account to access a range of products and services. Other privacy policies may also apply in addition to the terms of this Policy. Where we have a 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. We process personal information pursuant to service agreements that we have in place with our clients who have retained us to provide services on their behalf, including but not limited to transfer agency, plans administration, corporate actions, governance services, unclaimed property and proxy services. The personal information that you or our clients provide to us is used to perform the various services that are described in each service agreement.
2. How we collect your personal data
We may collect and process the following personal data about you:
Information you provide to us
- By filling in forms on our website(s) so that we may contact you;
- By corresponding with us by phone, e-mail, live-chat, social media channels or otherwise;
- Application/registration forms/identification documentation;
- Entering competitions, promotions or surveys; and
- When you report any problem or complaints with our website, products and services.
Information we collect about you
Information about how you logged on and off of our website(s), including your IP address, information about your visit, your browsing history, and how you use our website. This will include the capture of your location information – please see our cookie policy for further information on this;
Information on what you view, click on and access in and through our marketing emails. This may include the geographic location of the device you have used – please see our cookie policy for further information on this;
If you contact us via social media, we may collect details from your social media account.
Information we receive from third parties
As part of our identity and financial crime checking procedures with credit reference agencies, fraud detection agencies and registration or stockbroking industry exchanges;
From third parties when you have instructed or agreed for them to pass information to us or as part of their offering services to you.
From online advertising networks (for example Google) through whom we place advertisements. The information we obtain varies from network to network. It often summarises the actions of lots of people and so does not enable us to identify you individually. It relates to what you view, click on, and access through websites in their network, including the subject matter of the website you started at and where you subsequently go. It might also include their analysis of your behaviour across the wider internet and a profile of you.
From social networks where your account privacy settings allow us to validate and complete our records, as well as track information such as displaying and click on advertisements based on previous browsing history on this website.
We do not control the information on you that such networks obtain or the technology they use to do so. This website, like many others, does not track or respond to Do Not Track ('DNT') requests made through browser settings.
Sensitive types of data – The law and other regulations treat some types of personal information as sensitive. We will only collect and use this information if the law allows us to do so. Sensitive types of data are:
- Criminal convictions and offences;
- Genetic and bio-metric data;
- Health data including gender;
- Racial or ethnic origin;
- Religious or philosophical beliefs; and
- Trade union membership
Keeping your personal data up to date
The personal data we hold may include your name, postal address, email address and phone number, date of birth, financial information and employment details to enable us to contact you and respond to your enquiries as well as provide you with our products and services.
It is important to us that the personal data we hold about you remains accurate and up to date at all times, but we need your help in doing this. Please let us know as soon as anything needs updating or correcting.
Other people’s personal data
The information you give us, or that we collect through your use of our services, may contain your or another person’s personal data. If you provide us with information about another person, you confirm that they have appointed you to act for them, they consent to you providing their personal data to us and any processing of their personal data and that you have informed them of our identity and the purpose for which their personal data will be processed – as set out in this Privacy Notice.
3. Why we collect your personal data
In the following table we demonstrate why and how we use your personal data and provide the legal basis for such use.
| Type of processing | Purpose of the processing | Lawful basis for the processing of personal data |
| Provision of services, including the administration and management of customer records | To manage and operate your online account with us to facilitate the provision of services, this includes retaining records of your instructions and telephone calls and keeping your online account records up to date. To respond to any data rights that you invoke. To complete any transaction or instructions that you provide us, and any legal obligations we have in relation to the transactions / instructions. To keep our websites and portals secure and permit you safe access to our services. | The performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Our legitimate interests, such as the proper administration of our service and business, for example:
With your consent. |
| Marketing our products and services | To allow you to participate in interactive features of our website, when you choose to do so.
IMPORTANT You can withdraw from marketing at any time, please use the unsubscribe button in our emails or contact us using the details noted above. | With your consent. When we have collected your personal data as part of a transaction with us Our legitimate interests, such as the proper administration of our service and business, for example:
|
| Improving our products and services | To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website(s) or the website of another Equiniti Company or third parties’ websites. We may do this ourselves or appoint an agency to do this on our behalf. To identify service improvements such as when troubleshooting, undertaking data analysis, testing new products, using your personal data for research, statistical and survey purposes.
| With your consent. To comply with legal requirements placed upon us, such as the Data Protection legislation. Our legitimate interests, such as the proper administration of our service and business, for example:
Some of this information will be gathered by cookies that you have consented can access your computer. Please see our cookie policy for further information on how to manage cookies. |
If you choose not to give personal information
We need to collect personal information required by law or under the terms of service you have elected to use. If you choose not to give us the personal data we need we may have to cancel or decline a service that you request or that we provide. So that you know what information is optional, we make it clear at the time we collect your personal data.
5. How long we hold your personal data for
Personal data will not be retained for longer than necessary for us to achieve the purpose for which we obtained your personal data. We will then either securely delete it or anonymise it so that it cannot be linked back to you. We review our retention periods for personal data on a regular basis.
We will retain personal data for as long as is necessary for you to access your records and for the following reasons:
- To respond to enquiries and complaints;
- To demonstrate that your instructions were carried out properly; and
- To maintain records to meet rules and regulatory requirements that are applicable to the request you made or the service you were using.
We can keep your data for longer than stated above if we cannot delete it for legal, regulatory or technical reasons. We can also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes
For full details of our retention policies, please contact us using the contact details noted in 1. Who we are.
6. The conditions under which we may share your personal data with others
The personal data we hold about you is confidential, and we will only share your personal data to enable us to deliver our product(s) or service(s), examples are as follows:
- At your request, or with your consent;
- Other Equiniti Group companies who help us deliver our products and services, such as Equiniti India Private Limited;
- Non-Equiniti entities, in connection with accounts and services provided for you, including:
- Service suppliers to facilitate website, email, IT and administration services;
- Our professional advisors, for example, our lawyers and technology consultants, when they need it to provide advice to us;
- Your employer or agent(s), in accordance with any specific instructions you provide to us;
- Market Research Agencies to measure or understand the effectiveness of advertising we serve to you and others. We may do this ourselves or appoint an agency to do this on our behalf. This will include your use of social media sites;
- Credit reference agencies and fraud detection agencies as part of our identification procedures;
- Fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, can be obtain by contacting the Equiniti Data Protection Officer using the details noted below; and
- Your Official Receiver or appointed insolvency practitioner if we receive notice of your insolvency, bankruptcy or insolvency proceedings / arrangement
We will only transfer your personal information to trusted third parties who provide sufficient security guarantees that are at least as stringent as EQ’s standards and who demonstrate a commitment to compliance with applicable law and this policy. Where third parties are processing personal information on our behalf, they will be required to agree, by contractual means, to process the personal information in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representatives shall act only on our instructions, or as permitted by law.
We may also be required to share your personal data with external third parties as follows (but not limited to):
- Legal and/or regulatory authorities pursuant to applicable requests.
- We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. At all times, your privacy rights will be protected as per this Privacy Notice.
7. Overseas Processing
Equiniti uses data processors who are third parties providing services to us. We have contracts in place with our data processors which. restrict their ability to process your data except in accordance with our instructions and data privacy requirements.
Your personal information is processed and stored in the United States and may be transferred to, processed and stored in countries outside the United States by Equiniti’s service providers, all in accordance with this Privacy Policy. Personal data will be shared with members of the Equiniti Group outside of the United States, including Equiniti Limited, which is based in the United Kingdom, and Equiniti India Private Limited, which is based in India, for the purposes of processing and/or accessing data in order to provide you with services. We may also disclose your personal information to other overseas affiliates and service providers who assist us in supplying our services or who perform functions on our behalf, all in accordance with this Privacy Statement.
Our transfer of personal data to other countries could result in that personal data being available to governments and other authorities in those countries under their laws. By using our service, you agree to this international transfer, storing and processing.
EU/EEA/UK Residents
Please note that data protection laws do vary from country to country. In particular, the law of the country in which you are a resident or domiciled may offer a higher standard of protection than the laws in the United States and/or those other countries in which we store and use the personal data we collect. In addition to the information provided above, if you are a current resident of an EU/EEA/UK country, you may have certain rights regarding your personal information. EQ will assist our data controller clients, to the extent possible, with the fulfilment of their obligations to respond to your requests. These may include, depending on the circumstance, the right to access your personal information; rectify the personal information we hold about you; erase your personal information; restrict our use of your personal information; object to our use of your personal information; receive your personal information in a usable electronic format and transmit it to a third party (also known as the right of data portability); lodge a complaint with your local data protection authority; and withdraw any consent you have given to the uses of your personal information. If you would like to discuss or exercise the rights you may have, feel free to contact us at DPO@equiniti.com.
If you would like any further details about transfers of your personal data, then please contact our Data Protection Officer using the details provided at the end of this Privacy Notice.
By using our Service, you agree to this international transfer, storing and processing.
8. How we keep your personal data secure
We understand how important your personal data is to you and we take its security very seriously.
We safeguard your personal data across all our computer systems, networks, websites and offices as much as possible through appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques).
We also use secure ways of communicating with you such as when collecting your personal data or providing your account information:
- online through the use of ‘‘https’’ and other security and encryption protocols. This is indicated by a lock icon on the bottom of the web browser, or the address will include the letters https in the top left-hand corner; and
- before we discuss matters relating to your account(s) by telephone we will always ask you security questions to confirm your identity.
- Where we have given you (or where you have chosen) a password or unique identifier (PIN) which enables you to access certain parts of online services, you are responsible for keeping this password / PIN confidential, along with any username. We will never ask for your full password or PIN, and you must not divulge your full password to us or anyone else. We recommend that any password or PIN you set is not easily guessable and changed frequently (at least once a month).
Because we cannot guarantee the confidentiality of personal data sent on the internet you should never send your login details via email.
Security concerns
If you ever receive a communication from us by post, email or by phone that you are concerned it is not genuine, please contact us using the contact details in Section 12.
You must immediately inform us if you become aware, or suspect, that someone else has knowledge of your account details.
If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice about Identify Theft on the US Federal Trade Commission website.
9. Your personal data rights and how to exercise them
You have rights in respect of the personal data that we hold about you depending on where you reside. They include the right to request a copy of the information that we hold about you, to know about any automated decisions that are made about you and to change your marketing preferences at any time. Details about all of your rights are provided below.
Some of these rights are conditional and depend upon why we are processing your personal data. This means that we cannot always be able to respond to your request in the way that you want. For example:
If you ask us to erase your personal data and we are processing the information because we are legally required to do so, we may not be able to delete your personal data.
Your State Privacy Rights
In addition to the information provided above, please refer to the Consumer Privacy Law within the State you reside in for details of States consumer privacy rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Correct inaccuracies in their personal information, taking into account the information's nature processing purpose Data portability.
- Opt-out of personal data processing for:
- targeted advertising
- sales; or
- profiling in furtherance of decisions that produce legal or similarly significant effects.
- Either limit (opt-out of) or require consent to process sensitive personal data.
- The exact scope of these rights may vary by state. For our clients that meet the definition of a business or data controller under these relevant state privacy regulations, EQ will assist those clients, to the extent possible, with the fulfillment of their obligations to respond to your requests. EQ will not discriminate against consumers for exercising their rights under these state privacy regulations. If you would like to discuss or exercise any of these rights, please contact dpo@equiniti.com
10. Useful information
10.1 - Children (16 years and under) and Vulnerable Adults
Our sites and applications are not intended for children under 16 years of age. No one under age 16 may provide any personal information to the site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this site or through any of its features, register on the site, make any purchases through the site, or provide any information about yourself to us, including your name, address, 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 16 without verification of parental consent, we will delete that information.Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see refer to ‘Your State Privacy Rights’ for more information.
For more information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov
10.2 – Use of ‘cookies’
For full details of how we use cookies, please refer to our cookies policy
10.3 - Changes to this Privacy Notice
We review our use of your personal data regularly. In doing so, we can change what personal data we collect, how we keep it and what we do with it. As a result, we can change this Privacy Notice from time to time to keep it relevant and up to date.
By continuing to use our products and services, you will be bound by this Privacy Notice.
11. Contact Details
We hope that this Privacy Notice has been helpful in setting out how we handle your personal data and your rights to control it. If you have any questions that remain unanswered, please contact our Data Protection Officer:
- By email at DPO@equiniti.com,
- By post at Data Protection Officer, 28 Liberty Street, Floor 53, New York, NY 10005