Privacy Policy

We understand how important your personal data is and are committed to protecting and respecting your privacy.

Equiniti.com is the main website for the Equiniti Group of companies. This Privacy Policy explains how the companies of the Equiniti Group collect, use and protect your personal information across our brands. References to "we", "us" or "our" are to the relevant Equiniti Data Controller processing your personal information.

Equiniti is structured into four business divisions: UK Shareholder Services, US Shareholder Services, Retirement Solutions and Customer Resolutions. Usually when we interact with you it will be through one of these brands. The Equiniti Group legal entity that is responsible for your personal data (the data controller) will be the entity shown on the website, form or portal. Different Equiniti legal entities are responsible for different services and products.

This Privacy Policy applies globally and is intended to provide information regarding the collection, use, disclosure and protection of personal information. Additional information relating to specific jurisdictions, including the United Kingdom, European Economic Area and United States, is included within this Privacy Policy where required by applicable law.

By using this site, you acknowledge that you have read this Privacy Policy.

• How we collect your personal data;
• Why we collect your personal data;
• How long we hold your personal data for;
• The conditions under which we may share your personal data with others;
• Overseas Processing;
• How we keep your personal data secure;
• Your personal data rights and how to exercise them;
• Useful information.

1. 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, email, live-chat, social media channels or otherwise;
• Application, registration forms and identification documentation;
• Entering competitions, promotions or surveys; and
• When you report any problems or complaints with our website, products and services.

Information we collect about you

• Information about when you logged onto our website(s), including your IP address, information about your visit, browsing history and how you use our website. Please see our Cookie Policy for further information;
• Information on what you view, click on and access through our marketing communications. This may include the geographic location of the device you have used;
• Information collected through cookies and similar technologies;
• If you contact us via social media, we may collect details from your social media account where your privacy settings permit us to do so.
• Information relating to your use of our products, services and online portals.

Information we receive from third parties

• As part of our identity verification and financial crime checking procedures with credit reference agencies, fraud prevention agencies and registration or stockbroking industry exchanges;
• From third parties when you have instructed or agreed for them to pass information to us;
• From online advertising networks through which we place advertisements;
• From social networking sites where your account settings permit this;
• From members of the Equiniti Group where necessary to provide products and services;
• From employers, trustees, issuers, pension schemes, benefit providers, agents or authorised representatives.

We will only collect and use special category information or sensitive personal information where the law allows us to do so.

Keeping your personal data up to date

The personal data we hold may include your name, postal address, email address, telephone number, date of birth, financial information and employment details to enable us to contact you, provide services and respond to your enquiries.

It is important that the personal data we hold about you remains accurate and up to date. Please let us know if your personal information changes.

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 authorised you to act on their behalf, they consent to you providing their personal data to us and any processing of that information, and that you have informed them of the purposes for which their personal data will be processed as set out in this Privacy Policy.

2. Why we collect your personal data

In the table below we demonstrate why and how we use your personal data, together with the legal reasons upon which we rely where applicable.

The lawful bases listed below apply primarily to individuals in the UK, EEA and other jurisdictions with similar privacy laws. For individuals in the United States and certain other jurisdictions, we process personal information in accordance with applicable privacy laws for the purposes described in the "Purpose of Processing" column.

3. 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.

Retention periods vary depending on the type of personal data, the services provided, legal requirements and business needs.

For full details of our retention policies, please contact us using the contact details provided at the end of this Privacy Policy.

4. 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 include:

• At your request, or with your consent;
• Other Equiniti Group companies who help us deliver products and services;
• Service providers supporting our website, IT systems, communications and administration services;
• Professional advisers, including lawyers, auditors and consultants;
• Employers, trustees, issuers, pension schemes and authorised representatives where relevant;
• Market research agencies;
• Credit reference agencies and fraud prevention agencies;
• Banking partners and payment service providers;
• Regulators and supervisory authorities where required;
• Law enforcement agencies where required by law or to help prevent or detect crime.

We will only transfer your personal information to trusted third parties who provide sufficient security guarantees and who demonstrate a commitment to compliance with applicable law and this Privacy Policy.

Where third parties process personal information on our behalf, they are required by contract to process it only according to our instructions and to implement appropriate security measures.

We may also share personal data:

• To comply with legal obligations;
• In connection with legal proceedings;
• To establish, exercise or defend legal claims;
• To prevent or detect crime or fraud;
• Following a court order or regulatory requirement;
• As part of a merger, acquisition, reorganisation or sale of business assets.

At all times we will take reasonable steps to ensure your privacy rights continue to be protected.

5. Overseas Processing

Overseas Processing Statement

Some of our data processing occurs outside the country where the data originates. As a global organisation, Equiniti operates offices and processes data in multiple countries. We also work with third-party suppliers who may process data internationally.

When personal data is transferred across international borders, we implement robust safeguards to ensure compliance with applicable data protection laws. This includes using data transfer agreements, standard contractual clauses (SCCs), and conducting Transfer Risk Assessments (TRAs).

Examples of international data transfers include:

• Sharing personal data with members of the Equiniti Group outside the UK, such as Equiniti India Private Limited, for purposes described in this Privacy Notice.
• When you contact us by email or use our microsites, some of the service providers who support these services may be based outside the country where your data was originally collected.

Data Privacy Framework

For transfers to the US Equiniti complies with the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF, as set forth by the US Department of Commerce. Equiniti has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) and the UK Extension to the EU-US DPF, with regard to the processing of Personal Information received from the European Union and the United Kingdom in reliance on the EU-US DPF and the UK Extension to the EU-US DPF. If there is any conflict between the terms in this Privacy Statement and the EU-US DPF Principles and the UK Extension to the EU-US DPF, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

The legal entities of Equiniti that are adhering to the EU-U.S. DPF Principles, including as applicable under the UK Extension to the EU-U.S. DPF, and are covered by the Equiniti Trust Company, LLC DPF submission include: Amor Holdco, Inc., Armor Intermediate Company LLC, Armor Holding II LLC, Canadian Stock Transfer Holdings LLC, Equiniti (US) Holdings, LLC, Equiniti (US) LLC, DF King & Co, Inc, DF King Acquisition LLC, DF King Holding LLC, EQ Fund Solutions, LLC, LINK Shareholder Services, LLC and EQ Private Company Solutions, Inc.

In compliance with the EU-US DPF and the UK Extension to the EU-US DPF, Equiniti commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of Personal Information received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF.

Equiniti will arbitrate claims and follow the terms as set forth in the EU-U.S. DPF Principles and the UK Extension to the EU-US DPF, provided that an individual has invoked binding arbitration by delivering notice to Equiniti and following the procedures and subject to conditions set forth in Annex I of the EU-US DPF Principles and the UK Extension to the EU-US DPF. Under the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF Equiniti remains a liable party in cases of onward transfers to third parties if its supplier processes information in a manner that is inconsistent with the DPF principles, unless Equiniti proves that it is not responsible for the event giving rise to the damage. Equiniti is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC) regarding personal data received or transferred pursuant to DPF.

If you would like any further details about transfers of your personal data, then please contact our Data Protection Office at DPO@equiniti.com.

6. 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 personal data through appropriate technical and organisational measures designed to protect against unauthorised access, disclosure, alteration or destruction.

These measures may include:

• Encryption technologies;
• Secure communications;
• Access controls;
• Security monitoring;
• Data loss prevention measures;
• Employee training and awareness programmes;
• Incident management procedures.

Where we provide you with account credentials, passwords or security information, you are responsible for keeping those credentials confidential.

If you believe your account security may have been compromised, please contact us immediately.

7. Your personal data rights and how to exercise them

Privacy rights vary depending on where you are located. Further information regarding rights available under applicable privacy laws is set out below.

UK and EEA Privacy Rights

If UK GDPR or EU GDPR applies to the processing of your personal data, you may have the right to:

• Right to be Informed
• Right of Access
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Data Portability
• Right to Object
• Right in relation to Automated Decision Making and Profiling

If you remain dissatisfied following our response, you have the right to raise a complaint with the relevant supervisory authority.

Information Commissioner's Office (ICO)

www.ico.org.uk

US Privacy Rights

Residents of certain US states may have additional privacy rights under applicable laws.

These rights may include:

• Right to Know and Access Personal Information
• Right to Correct Inaccurate Personal Information
• Right to Deletion
• Right to Appeal
• Right to Non-Discrimination
• Right to Limit Use and Disclosure of Sensitive Personal Information
• Right to Opt-Out of Sale, Sharing, Targeted Advertising and Certain Profiling Activities
• Right to Data Portability

Where state-specific requirements apply, additional disclosures may be provided.

If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection Office.

If you remain dissatisfied with our response, you may have the right to contact a regulator or enforcement authority responsible for privacy matters in your jurisdiction.

You may report concerns relating to privacy, fraud or deceptive business practices to the Federal Trade Commission.

By email: ReportFraud.ftc.gov

By Post: Federal Trade Commission, 600 Pennsylvania Avenue, NW, Washington, DC 20580 or by calling: 1-877-FTC-HELP (382-4357).  

8. Useful information

8.1 Children and Vulnerable Adults

We are committed to protecting the privacy of children and vulnerable adults. We will only collect and use their personal data where the appropriate permissions are in place.

8.2 Use of Cookies

Our websites use cookies and similar technologies to support website functionality, improve user experience, analyse traffic and support marketing activities.

For further information, please refer to our Cookie Policy.

8.3 Changes to this Privacy Policy

We regularly review how we collect, use and protect personal information.

As our business, services and legal obligations evolve, we may update this Privacy Policy from time to time.

The latest version will always be available on our website.

By continuing to use our products and services, you will be bound by the current version of this Privacy Policy.

Contact Details

You can contact our Data Protection Officer at the details below if you require further information about privacy compliance at Equiniti or have any questions that remain unanswered:

• By email DPO@equiniti.com

United Kingdom

• By Post Data Protection Officer, PO Box 5243, Worthing, BN99 9FY

United States

• Data Protection Officer, 28 Liberty Street, 53rd Floor, New York, NY 10005

EU Representative 

If you are located in the European Union you can contact Equiniti’s EU representative. Notified is Equiniti’s designated EU representative under Article 27 of the EU GDPR, located in France. 

• By email DPO@equiniti.com
• By Post Notified, Legal Department, 4 Rue Charras, Paris 75009, France