www.dfinsolutions.com Open in urlscan Pro
54.83.189.142  Public Scan

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          <br> A representative will contact you shortly.
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PRIVACY NOTICE

Last Updated: May 4, 2021

--------------------------------------------------------------------------------


SELECT YOUR LANGUAGE PREFERENCE

English (US)English (UK)Select

Donnelley Financial Solutions, Inc. and its worldwide subsidiaries (DFIN)
respect your privacy and know that you care about how we use and share your
information. This notice describes how DFIN collects, shares, uses and protects
personal information. By using this website and other websites that we operate
and where we post a direct link to this Privacy Notice (Our Site), you are
accepting and consenting to the practices described in this Privacy Notice.

Our Privacy Notice explains:

 * Personal information we collect, and why we collect it.
 * Recruitment.
 * Cookies and other technologies.
 * How we use your personal information.
 * How we share your personal information.
 * Third Party Websites.
 * How we protect your personal information.
 * How long we keep your personal information.
 * Your rights and choices.
 * Data transfers.
 * How we monitor and enforce.
 * California Consumer Privacy Act (California).
 * New York SHIELD Act (New York).
 * PIPEDA (Canada).
 * GDPR (EU).
 * Children’s Online Privacy Protection Act (COPPA).
 * Changes to this privacy notice.
 * How to contact us.


PERSONAL INFORMATION WE COLLECT AND WHY WE COLLECT

Information you give us. This is information about you that you provide to us by
filling in forms on our site DFINsolutions.com, participating at events
organized or attended by DFIN, corresponding with us by phone, electronic mail
or otherwise or visiting our offices. It includes information that you provide
when you register to use our site, subscribe to our service, engage in social
media functions on our site or other activities commonly carried out on the
site, as well as when you report a problem with our site.

Personal information, also known as personally identifiable information (PII) or
personal data, for purposes of this Privacy Notice, means any information that
(i) directly and clearly identifies an individual, or (ii) can be used in
combination with other information to identify an individual. Personal
information does not include such information if it is anonymous or if it has
been rendered de-identified by removing personal identifiers.

The information you provide may include basic personal information such as your
name, address, e-mail address, phone number, title and company. DFIN may collect
more sensitive information from you such as financial and credit card
information, social security and other government identification numbers where
it is appropriate or necessary for conducting business. DFIN limits its
collection and use of personal information to the minimum identifiers that are
necessary for performing the specific task related to the purpose for which the
personal information is collected.

Information we collect about you. With regard to each of your visits to our
site, we may automatically collect information such as:

 * Technical information, including the Internet Protocol (IP) address used to
   connect your computer to the Internet, source domain names, your login
   information, browser type and version, time zone setting, length of time
   spent on our site and operating system and platform.
 * Information about your visit even if you have not created an account or
   logged in, including the full Uniform Resource Locators (URL), specific web
   pages, clickstream to, through and from our site including date and time,
   products and services you viewed or searched for, page response times,
   download errors, length of visits to certain pages and any phone number used
   to call our customer service number.

DFIN may also supplement the personal information we collect from you with
information we receive from third parties, including our business partners,
contractors, analytics and other service providers.

We process personal information for certain legitimate reasons as well as to
help us improve the overall accuracy of the information and its completeness,
better tailor our interactions with you and to identify and prevent fraud.

The information assists in enhancing the security of our information systems and
assessing the effectiveness of our promotional and advertising campaigns. The
information is also used to aggregate statistical data, facilitate system
administration and improve our site.


RECRUITMENT

When you apply for an employment opportunity at DFIN, we may collect certain
personal information from your job application through our Careers site or when
you apply through an agent or other third-party platforms. Such personal
information may include name, postal address, email address, phone number,
details of your qualifications, job history, curriculum vitae, contact details
of your references and any other personal information submitted along with your
application.

We may also collect this information from, where applicable, your personal
references (provided by you), your educational institute, or any other relevant
professional body.

DFIN processes your personal information as necessary for the purposes of
fulfilling certain legal obligations related to recruitment, for example where
employment law or other laws require the processing of your personal
information. We may process personal information due to reliance on our
legitimate business interests in the selection, evaluation and appointment of
new employees, and the management and administration of recruitment and HR
processes. On occasion, legal grounds such as protection of your vital interests
may also apply. For example, for health and safety reasons, if you attend an
interview at one of our offices or in relation to agreements with employee
representation groups, if applicable.

We retain the personal information that we obtain about you during the
recruitment process for no longer than is necessary for the purposes for which
it is processed. The duration for which we keep your information will depend on
whether your application is successful and you become employed by us, the nature
of the information concerned, and the purposes for which it is processed.


COOKIES AND OTHER TECHNOLOGIES

When you visit our site, we may automatically collect information such as your
IP address, browser type and language, operating system, location, date and time
using cookies. A cookie is a small amount of data that is sent to your browser
from a web server and stored on your device such as a phone or computer. The
cookies are then sent back to the originating website on each subsequent visit
to that website. As an example, a cookie may allow us to recognize your browser,
whereas another cookie may store your preferences. This helps us to provide you
with a good experience when you browse our site and allows us to improve our
site. Cookies are a technology that can be used to help personalize your use of
our site.

For more information, please refer to our Cookie Policy.


HOW WE USE YOUR PERSONAL INFORMATION

DFIN uses, stores and processes the personal information we collect to:

 * Where relevant, operate and provide DFIN’s products and services.
 * Where relevant, register you as a customer.
 * Perform our obligations under a contract with you.
 * Provide you with information, products and services which you request from us
   or similar products or services which you have already requested.
 * Where appropriate, provide you with marketing communications for products and
   services from DFIN, including personalized offers and content based on your
   interactions with us and usage of our products.
 * Enforce or apply the terms of any of our user agreements.
 * Improve our existing services and the content of our site.
 * Help solve any issues that you might be facing.
 * Protect the rights, property or safety of DFIN, DFIN’s users, or others.
 * Manage our everyday business needs, such as for our internal account
   management, client reporting, contract management, website administration,
   business continuity and disaster recovery, security and fraud prevention,
   corporate governance, reporting and legal compliance.

DFIN reserves the right to transfer and disclose your information if DFIN
becomes involved in a business divestiture, change of control, sale, merger, or
acquisition of all or a part of its business.

When we use your personal information for the purposes specified above, we do so
on the basis of:

 * Consent: where you have given us clear consent for us to process your
   personal information for a specific purpose.
 * Contract: where our use of your personal information is necessary for a
   contract we have with you, or because you have asked us to take specific
   steps before entering into a contract.
 * Legal obligation: where our use of your personal information is necessary for
   us to comply with the law.
 * Vital interests: where our use of your personal information is necessary to
   protect you or someone else’s life.
 * Legitimate interests: where our use of your personal information is necessary
   for our legitimate interests or the legitimate interests of a third party.

Please note that if you do not provide us with certain personal information,
depending on the purposes for which we have collected it, we may not be able to
provide the information, products or services you have asked for or process your
requests, applications, subscriptions or registrations, and may not be able to
perform or discharge applicable legal obligations.


HOW WE SHARE YOUR PERSONAL INFORMATION

DFIN may have to share your personal information with entities and persons set
out below, for the purposes listed herein. We may share your personal
information we collect about you with:

 * Our affiliates, subsidiaries, vendors, consultants and other service
   providers to perform the services on our behalf and to ensure the efficient
   operation of our business.
 * Where required, with professional advisors or consultants, including lawyers,
   banks, auditors, accountants and insurers providing consultancy, legal,
   banking, audit, accounting or insurance services to us; any person or entity
   to whom we are required or requested to make such disclosure by any court of
   competent jurisdiction or by any governmental, taxation or other regulatory
   authority, law enforcement agency or similar body.
 * Service providers who provide information technology and system
   administration services to us.

DFIN may share your information in response to a request for information, if
upon review we determine that disclosure is in accordance with, or required by,
any applicable law, regulation or legal process.

DFIN may share your personal information in connection with or during
negotiations of any merger, sale of company assets, financing or acquisition of
all or a portion of our business by another company.

We may also share your personal information with our customers when they need
access to such information to fulfil specific transactions related to services
you requested such as promotional campaigns. You may opt out of sharing your
information with our customers for related services by sending an email to
dataprivacy@dfinsolutions.com. Upon receipt of your request to opt out of this
information sharing, we will acknowledge your request and take appropriate
measures in response.

We may also share your personal information if we determine that your actions
are inconsistent with our user agreements or policies, or if we must protect the
rights, property and safety of DFIN or others in accordance with, or required
by, any applicable law, regulation or legal process.


THIRD PARTY WEBSITES

DFIN may post links to third party websites as a service to you. These third
party websites are operated by companies that are outside of our control, and
your activities at those third party websites will be governed by the policies
and practices of those third parties. We encourage you to review the privacy
policies of these third parties before disclosing any information, as we are not
responsible for the privacy policies of those websites.


HOW WE PROTECT YOUR PERSONAL INFORMATION

The security of your personal information is important to us. We use reasonable
physical, electronic and procedural safeguards to protect the personal
information we collect from loss, theft, misuse, alteration and unauthorized
access or destruction. In addition, we maintain appropriate physical,
electronic, and procedural safeguards to protect your personal information,
including:

 * Restricting access to personal information to our employees or service
   providers on a “need-to-know” basis.
 * Enforcing policies and procedures for our employees in their handling of
   personal information.
 * Using technologies designed to safeguard data during its transmission, such
   as SSL encryption for the information you provide on some parts of our site
   and using appropriate security to safeguard the data that we have received.

DFIN also employs industry-standard measures and processes for detecting and
responding to inappropriate attempts to breach our systems.

There is, however, no method of transmission over the Internet, or method of
electronic storage that can be 100% secure. Therefore, DFIN cannot guarantee the
absolute security of your information. The Internet by its nature is a public
forum, and DFIN encourages you to use caution when disclosing information
online. Often, you are in the best situation to protect yourself online. You are
responsible for protecting your username and password from third party access,
and for selecting passwords that are secure.


HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will keep your personal information while you have an account with us or we
are providing products services to you. Thereafter, we will keep your personal
information for as long as is necessary to:

 * Respond to any questions, complaints or claims made by you or on your behalf.
 * Keep records required by applicable laws and regulations.

We will not retain your personal information for longer than necessary for the
purposes set out in this privacy notice.


YOUR RIGHTS AND CHOICES

You may have the right to access and review the personal information stored by
us to confirm its accuracy, and if necessary you may request that personal
information is updated if it is inaccurate. You may also request that certain
personal information be deleted from our files. You may be required to log into
your account to exercise these rights, or contact us at
dataprivacy@dfinsolutions.com.

DFIN will make reasonable efforts to comply with such requests, unless such
requests are prohibited by law, or there is a legitimate business purpose to
retain personal information. We reserve the right to verify your identity before
any request to update or delete your personal information is processed by us.
Please direct any questions about your personal information to DFIN’s Global
Privacy department at dataprivacy@dfinsolutions.com.

In accordance with this Privacy Notice, but excluding any transfers of data to
third parties performing tasks directly on our behalf and pursuant to our
instructions, where we receive personal information directly from an individual
to which such personal information relates, where applicable, we will offer the
individual the opportunity to choose (opt out) whether his or her personal
information is (1) disclosed to a third party; or (2) used for a purpose that is
materially different than the purpose it was originally collected or
subsequently authorized by the individual.

Any individual who wishes to opt out can do so by contacting DFIN at the address
provided below under the section of this Privacy Notice entitled “HOW TO CONTACT
US”.

In situations where we receive personal information pertaining to individuals
directly from our clients (and not the individual to whom the personal
information relates), we will cooperate with our clients’ reasonable requests
to:

 * Assist them in informing the impacted individuals about (a) the possibility
   that we may disclose such individuals’ information to third parties and (b)
   the individual’s ability to opt out of such disclosures (except for
   disclosures to third parties performing tasks directly on our behalf and
   pursuant to our instructions).
 * Reasonably ensure that we process the information for purposes compatible
   with the purposes for which it was originally collected or subsequently
   authorized by the impacted individuals. After we have notified our clients,
   they will then inform us if any individuals have opted out of such
   disclosures.

In situations where DFIN processes “sensitive personal information” (which may
include personal information relating to medical or health conditions, racial or
ethnic origin, political opinions, religious or philosophical beliefs, trade
union membership, the sex life of the individual, ideological views or
activities, social security measures pertaining to an individual, or
administrative or criminal proceedings and sanctions), we will seek informed
express consent (opt in) from individuals if such information is to be disclosed
to a third-party (except for disclosures to third parties performing tasks
directly on our behalf and pursuant to our instructions) or used for purposes
that are materially different from the purpose it was originally collected or
subsequently authorized by the individual.


DATA TRANSFERS

DFIN is a global organization with legal entities and business processes in
operation across borders and cannot always limit the processing of personal
information to the country in which an individual is based. In the course of
providing you services, DFIN may need to transfer personal information to
locations outside the jurisdiction in which it is provided or where our site is
viewed. We comply with applicable legal requirements providing adequate
safeguards for the transfer of personal information to countries other than the
country where you are located.

Data transfers between the U.S., EU, and other countries will only be done
subject to compliance with applicable law and appropriate technical and
organization safeguards of such data. This includes onward transfers to third
parties. DFIN requires our third parties to implement the necessary safeguards
to best protect personal information both in transit and at rest. In the event
that such onward transfers are not conducted per our terms, we acknowledge that
we may be liable for any resulting outcomes.

DFIN complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department
of Commerce regarding the collection, use, and retention of personal information
transferred from the European Union and the United Kingdom and/or Switzerland to
the United States in reliance on Privacy Shield. DFIN has certified to the
Department of Commerce that it adheres to the Privacy Shield Principles with
respect to such information. If there is any conflict between the terms in this
privacy policy and the Privacy Shield Principles, the Privacy Shield Principles
shall govern. eBrevia, a wholly subsidiary of DFIN, also adheres to the Privacy
Shield Principles. To learn more about the Privacy Shield program, and to view
our certification, please visit https://www.privacyshield.gov/.

 * In compliance with the Privacy Shield Principles, DFIN commits to resolve
   complaints about our collection or use of your personal information at no
   cost to the individual. EU, United Kingdom (UK) and Swiss individuals with
   inquiries or complaints regarding DFIN’s use of their personal information
   should contact our Global Privacy department at
   dataprivacy@dfinsolutions.com. DFIN will respond to your inquiry within 45
   days.

In the event of a reported complaint that DFIN does not resolve itself, DFIN
commits to cooperate with the EU Data Protection Authorities (DPAs), UK
Information Commissioner’s Office (ICO) and Swiss Federal Data Protection and
Information Commissioner (FDPIC). We will comply with the advice given by each
respective regulatory body with regard to human resource (HR) and non-human
resource data transferred from the EU and UK. As well as non-human resource data
transferred from Switzerland to DFIN in the U.S. DFIN has chosen the EU DPAs to
serve as an independent recourse mechanism (IRM) for dispute resolution. We have
designated the United States Council for International Business (USCIB) to act
as the trusted third party for this purpose.

Under certain conditions, more fully described on the Privacy Shield website,
you may invoke binding arbitration when other dispute resolution procedures have
been exhausted. DFIN is accordingly subject to the investigatory and enforcement
powers of the U.S. Federal Trade Commission (FTC). In certain circumstances,
DFIN may also be subject to the investigatory and enforcement powers of the U.S.
Department of Transportation or any other U.S. authorized statutory body.

DFIN takes appropriate technical and organizational measures to safeguard all
personal information against unauthorized or unlawful processing of, or
accidental loss, damage, misuse, unauthorized access, unauthorized disclosure,
unauthorized alteration, or destruction, and maintains reasonable procedures to
help ensure that such information is relevant for its intended use, accurate,
complete, current and not excessive and that such information is not retained
longer than is reasonably necessary.

With respect to any sharing of business contact information for the purposes of
marketing DFIN products and services, DFIN obtains assurances from its
affiliates, subsidiaries and business partners that such entities will use and
disclose such business contact information for purposes of marketing DFIN
products and services only. In alignment with our Privacy Shield certification,
we acknowledge that we may be required by applicable law to disclose personal
information in response to lawful requests by public authorities, including to
meet national security or law enforcement requirements. DFIN agrees to work
effectively with these parties to support their initiatives and ensure any data
is processed lawfully.


HOW WE MONITOR AND ENFORCE

DFIN regularly reviews our compliance with our Privacy Notice. We also adhere to
several self-regulatory frameworks in addition to complying with applicable
laws. If we receive formal written complaints, we will follow up with the person
making the complaint. We work with the appropriate regulatory authorities to
resolve any complaints that cannot be resolved directly.


CALIFORNIA CONSUMER PRIVACY ACT (CALIFORNIA)

The California Consumer Privacy Act of 2018 (CCPA) went into effect on January
1, 2020. CCPA provides California residents with specific rights regarding their
personal information. Please refer to DFIN’s CCPA Notice for more information.


NEW YORK SHIELD ACT (NEW YORK)

The New York Stop Hacks and Improve Electronic Data (SHIELD) Security Act went
fully into effect on March 21,2020. The SHIELD Act applies to any person or
business that owns or licenses computerized data which includes private
information, regardless of corporate structure, revenues or location. DFIN
conducts business within New York (NY) state and has realigned its processes and
procedures to adhere to the requirements established within the SHIELD Act to
support the protection of New York residents’ personal and private information.

Under the SHIELD Act, businesses are required to have an established security
program and provide proper notice in the event of a data breach involving any
New York resident’s private information. DFIN has a strong and robust security
program that works diligently to protect the personal information of all
individuals. Proper controls and safeguards are in place that align with the
requirements under the SHIELD Act. These controls and safeguards provide
essential protection over New York residents’ private information. A breach
notification process has also been established to address reporting requirements
under the SHIELD Act.


PIPEDA (CANADA)

DFIN recognizes and has controls in place to ensure that the privacy of personal
information about an “identifiable individual” used in the course of “commercial
activity” is protected and managed in such a manner which meets or exceeds the
guidelines set out in Canada’s Personal Information Protection and Electronic
Documents Act (PIPEDA) and applicable provincial legislation.


GDPR (EU)

DFIN may act as a Controller or a Processor under the General Data Protection
Regulation (GDPR). In respect of business customers located in the U.S., UK and
EU and other locations worldwide, DFIN operates as a data processor. DFIN’s
business customers remain the data controllers with respect to any customer data
that they provide to DFIN for our provision of services. DFIN therefore acts in
accordance with the instructions of such customers regarding the collection,
processing, storage, deletion, access, rectification, portability and transfer
of customer data.

DFIN is a global entity with offices in five continents around the globe,
including over ten offices (and correspondent offices) in the EU. The handling
and safeguarding of personal data concerning EU-based citizens is a matter of
course for the business globally and an integral part of DFIN’s corporate
governance.


CHILDREN’S ONLINE PRIVACY PROTECTION ACT – COPPA

DFIN does not sell or offer its services and products to children. As such, our
sites are designed for adult user interaction. We do not intentionally collect
personally identifiable information from children under the age of 13. If you
are a parent or legal guardian of a minor under the age of 13 and believe that
the minor has disclosed personal information to us, please contact us by
following the “How to Contact Us” below.


CHANGES TO THIS PRIVACY NOTICE

DFIN reserves the right at its absolute discretion to change this Privacy Notice
from time to time. If this Privacy Notice changes, the revised version will be
posted at the “Privacy Notice” link on our site’s home page. In the event that
the change is significant or material, we will notify you of such a change by
revising the link on the home page to read “Newly Revised Privacy Notice.”
Please check the Privacy Notice frequently. Your continued use of our sites
constitutes acceptance of such changes in the Privacy Notice, except where
further steps are required by applicable law. This Privacy Notice was last
updated on May 4, 2021.


HOW TO CONTACT US

If you have any questions regarding DFIN’s privacy practices, the use of your
personal information, or about this Privacy Notice, please contact us at:

Donnelley Financial Solutions (DFIN)
Global Data Privacy
35 West Wacker Drive
Chicago, IL 60601
United States of America
Email: dataprivacy@dfinsolutions.com
Phone: 855-683-9454

For country specific inquiries, please contact:

Brazil
Fernando Ribeiro
Email: dataprivacy@dfinsolutions.com
Phone: 855-683-9454

EU
Paul Maloney (VP Europe and APAC GIM Ops)
Email: dataprivacy@dfinsolutions.com
Phone: 855-683-9454

Singapore
Robin Yeo (DPO)
Email: dataprivacy@dfinsolutions.com
Phone: 855-683-9454

South Korea
JungYun Moon (DPO)
Email: dataprivacy@dfinsolutions.com
Phone: 855-683-9454




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