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Submitted URL: http://www.broadridge.com/privacy.asp
Effective URL: https://www.broadridge.com/legal/privacy-statement-english
Submission: On January 25 via api from US — Scanned from DE
Effective URL: https://www.broadridge.com/legal/privacy-statement-english
Submission: On January 25 via api from US — Scanned from DE
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</form>Text Content
Frankfurt am Main DE 50.1049 8.6295 HE 60326
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* Financial Services
Expert solutions for financial services for over five decades
* Asset Management
Institutional Investors
* Manage operational risk
* Engage investors effectively
* Drive profitability with automated revenue and expense management
* Enhance and simplify portfolio management
Mutual Funds and ETF Providers
* Access unique distribution insights
* Maximize marketing communications
* Drive a successful proxy outcome
* Enhance and simplify portfolio management
* Drive profitability with automated revenue and expense management
* Maximize investor communications
* Simplify regulatory reporting
Retirement Services Providers
* Optimize trade processing
* Maximize participant and plan sponsor engagement
* Equip advisors to grow their business
Global Investment Managers
* Enhance and simplify portfolio management
* Manage risk and optimize operational efficiency
* Drive profitability with automated revenue and expense management
Alternative Managers
* Manage risk and optimize operational efficiency
* Enhance and simplify portfolio management
Fund Administrators and Prime Brokers
* Adapt to growing investment complexity and regulatory burden
* Support operational control and scalability
CLO Managers
* Enhance and simplify portfolio management
* Manage risk and optimize operational efficiency
Private Debt
* Enhance and simplify portfolio management
* Manage risk and optimize operational efficiency
Private Equity
* Optimize operational efficiency and manage the entire fund lifecycle
* Capital Markets and Banking
* Front-office trading and connectivity
* Enhance accuracy and visibility across the entire data life cycle
* Optimize operating model with financial services business process
outsourcing
* Streamline trade support, governance and compliance services
* Transform trade life cycle
* Empower transformation with expertise
* Consumer Finance
* Transform your print and digital communications
* Gain a single view of customer identities and preferences
* Deliver relevant, personalized digital and print communications
* Turn information into intelligence
* Reach customers across print and digital channels
* Measure the impact of your communications
* Take your customers to the next level
* Insurance
* Transform your print and digital communications
* Gain a single view of customer identities and preferences
* Deliver relevant, personalized digital and print communications
* Turn information into intelligence
* Reach customers across print and digital channels
* Measure the impact of your communications
* Take your customers to the next level
* Retail Banking
* Transform your print and digital communications
* Gain a single view of customer identities and preferences
* Deliver relevant, personalized digital and print communications
* Turn information into intelligence
* Reach customers across print and digital channels
* Measure the impact of your communications
* Take your customers to the next level
* Wealth Management
Wealth Management Firms
* Enhance advisor marketing
* Tackle your Reg BI obligations with confidence
* Enhance the client experience with dynamic advisor tools
* Transform communications
* Advance control, risk and support services
* Transform your trade life cycle
* Optimize your operating model with business process outsourcing
* Empower your transformation with confidence
Individual Advisor Solutions
* Build your practice
Retirement Services Providers
* Optimize trade processing
* Simplify regulatory and compliance reporting
* Maximize participant and plan sponsor engagement
* Equip advisors to grow their business
Trust Services Providers
* Optimize business operations
* Corporations
Streamline shareholder communications and management
* Corporate Issuer
* Simplify the annual meeting process
* Drive a successful proxy outcome
* Simplify transfer agent services
* Build your brand and engage shareholders
* Gain insights and uncover opportunities
* Streamline communications to drive down cost
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* Maximize ESG impact and bolster long-term sustainability
Corporate Treasury
* Increase efficiencies in managing cash and risk
Law Firms
* Streamline proxy and annual meeting services for your clients
* Take companies public with single-source simplicity
* Simplify capital markets and annual compliance disclosure
Non-Listed Issuer
* Enhanced shareholder engagement for alternative investments
* Healthcare
Improve the member and patient experience across the wellness journey
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* Onboard members with personalized documents and experiences, including ID
cards and welcome kits
* Make an impact with your correspondence, statements, bills and wellness
programs
* Optimize and customize patient communications, including statements,
Explanation of Payment (EOP) and claims
* Achieve optimal results with a dedicated team of consulting experts
* Telecom
Attract, engage and retain customers by creating dynamic experiences.
* Transform your print and digital communications
* Gain a single view of customer identities and preferences
* Deliver relevant, personalized digital and print communications
* Turn information into intelligence
* Reach customers across print and digital channels
* Measure the impact of your communications
* Take your customers to the next level
* Utilities
Deliver exceptional experiences across communication channels
* Transform your print and digital communications
* Gain a single view of customer identities and preferences
* Deliver relevant, personalized digital and print communications
* Turn information into intelligence
* Reach customers across print and digital channels
* Measure the impact of your communications
* Take your customers to the next level
* All Products
Transform your business with communications, technology, data and analytics
solutions
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* * 15(C) BOARD REPORTING
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* For Mutual Funds and ETF Providers
* * 22C-2 COMPLIANCE
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* For Mutual Funds and ETF Providers
* For Retirement Services Providers
* Advisor Compensation
* Advisor Desktop Solutions
* * ADVISOR RESOURCE CENTER
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* Advisor Targeting
* * ADVISOR WEBSITES
* For Individual Advisor Solutions
* For Wealth Management Firms
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* * ANNUAL COMPLIANCE
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* Anti-Money Laundering Solution (AMLS)
* * ASSET SERVICING
* For Capital Markets
* For Wealth Management Firms
* Association Election Management
* * BANK DEBT AND LOAN TRADING
* For Alternative Managers
* For CLO Managers
* For Fund Administrators and Prime Brokers
* Banking Book Collateral Management
* * BENEFICIAL PROXY SERVICES
* For Corporate Issuer
* For Law Firms
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* For Wealth Management Firms
* * BILLING AND EXPENSE MANAGEMENT
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* For Wealth Management Firms
* Branded Shareholder Portal
* Broadridge Intelligent Analytics
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* * CAPITAL MARKETS DISCLOSURES
* For Corporate Issuer
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* * CASH MANAGEMENT
* For Capital Markets
* For Wealth Management Firms
* Client Information Management
* Client Portal
* * COLLATERAL MANAGEMENT
* For Capital Markets
* For Global Investment Managers
* For Institutional Investors
* For Private Debt
* For Wealth Management Firms
* Collective Investment Trusts
* Communications Consulting
* Compliance and Regulatory Accounting
* Compliance and Regulatory Accounting Process Outsourcing
* Compliance Reporting
* Composition and Automated Publishing for Marketers
* * COMPOSITION AND PUBLISHING FOR LEGAL DOCUMENTS
* For Mutual Funds and ETF Providers
* For Mutual Funds and ETF Providers
* * CONNECTIVITY
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* * CONSUMER PREFERENCE AND PROFILE MANAGEMENT
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* Content Design and Management
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PRIVACY STATEMENT
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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 or security of your personal information, please
contact the Broadridge Privacy Office via email at privacy@broadridge.com.
1. BROADRIDGE PRIVACY STATEMENT
2. BROADRIDGE COOKIE NOTICE
3. BROADRIDGE CORPORATE ISSUER SOLUTIONS INFORMATION SECURITY PROGRAM
4. IMPORTANT INFORMATION FOR EEA, UNITED KINGDOM AND SWISS RESIDENTS
5. IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
6. HOW TO CONTACT US AND OUR CHIEF PRIVACY OFFICER
BROADRIDGE PRIVACY STATEMENT
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:
* Contact Information that allows us to communicate with an individual, such as
name, username, mailing address, telephone numbers, email address or other
addresses that allow us to send messages.
* Relationship Information that helps us do business with you, our clients and
service providers, such as professional credentials, as well as the types of
products and services that may be of interest.
* Transaction Information about how you and our clients interact with
Broadridge, including purchase history, client account information and
information about use of our websites and applications.
* Online and Technical Information, such as an IP address, network activity and
the data we collect using cookies and similar technologies.
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
When you use our websites, products and applications, Broadridge collects
personal information so that we may provide you or our clients with, or contact
you about, products, services and information, to enhance your site visit or
follow up with you after your visit. We also collect transaction information
about your session and your activity. In addition to any information that you
submit during these sessions, we use cookies and other technological tools to
automatically collect information about your computer and your use of our
websites, products and applications. We may also infer information about you
from your use of our websites, products and applications. We treat this
information as personal information when it is associated with other data
elements that allow us to identify you. For more information about cookies and
other technologies, please see our Cookie Notice.
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 privacy@broadridge.com if you would like to learn more about our
cross-border transfers.
Mobile Applications
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.
Marketing Communications
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 info@broadridge.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:
* You have the right to be informed about our collection, use and disclosure of
your personal information.
* You have a right to know if we maintain your personal information. If we do
have your personal information, we will provide you with a copy (subject to
the rights of others) as required by law. If your personal information is
incorrect or incomplete, you have the right to ask us to update it. You may
have the right to receive a copy of your personal information we maintain in
a portable format.
* You have the right to object to our processing of your personal information.
If we are processing your personal information based on your consent, you may
withdraw your consent at any time.
* You can control our collection of information via cookies using our Cookie
Management Tool.
* You may also ask us to delete or restrict your personal information.
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 privacy@broadridge.com. 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.
Information Security
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.
Data Retention
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 privacy@broadridge.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.
In particular:
* Access to Social Security numbers is limited to those associates and service
providers who have a need to access the information to perform tasks for
Broadridge.
* Social Security numbers are only disclosed to third parties in accordance
with Broadridge’s established policies. Broadridge will only disclose Social
Security numbers to those service providers, auditors, advisors, and/or
successors in interest who are legally or contractually obligated to protect
them or as required or permitted by law.
Other sites
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 privacy@broadridge.com or Human Resources Department to get information about
Broadridge’s Human Resources privacy practices.
BROADRIDGE COOKIE NOTICE
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.
Cookies
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.
Google Analytics
Google Analytics is a web analytics tool provided by Google, Inc. that helps
website owners understand how visitors engage with their website. Broadridge may
use Google Analytics to view a variety of reports about how visitors interact
with our websites so that we can improve them. Google Analytics uses cookies and
other tools, which generate information about your use of our website (including
your IP address). This information is transmitted to and stored by Google on
servers in the United States. Google uses this information to evaluate your use
of our website, report on website activity and provide other services to us.
Google may also transfer this information to third parties where required to do
so by law, or where such third parties process the information on Google’s
behalf. Google may combine this information with other data held by Google
pursuant to Google’s privacy policy available on Google’s website. You may
refuse the use of cookies by opting-out of our collection of data via
Performance and Targeting Cookies, using our Cookie Management Tool. For more
information on how Google Analytics uses the information it collects, please
visit “How Google uses information from sites or apps that use our services”,
located at www.google.com/policies/privacy/partners/.
Other Third Party Relationships
Segment is an analytics tool provided by Segment.io, Inc. that helps Broadridge
collect and manage information about how visitors interact with our websites and
marketing communications. Some of Segment’s data collection is facilitated by
cookies, JavaScript libraries or web beacons and pixels. Broadridge also uses
Segment to more efficiently route data to other services, and to control how
data is exchanged between these services. This data may include information
about the identity of users (such as name, postal address, e-mail address, IP
address and phone number), as well as information about the websites they visit,
the features they use, and the actions they take.
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 INFORMATION SECURITY PROGRAM
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:
* Shareholder name and address(es);
* Shareholder taxpayer identification number;
* Information related to the shareholder’s share ownership, history, and/or
dividends;
* In some cases, shareholder telephone numbers and/or e-mail addresses;
* In some cases, shareholder bank or brokerage account information; and
* In some cases, information from tax-related documents that is required to
process tax reports and statements, stock transfers, and other securities
transactions.
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:
* When necessary to effect, administer, or enforce a transaction requested by
the shareholder;
* When the shareholder requests or authorizes that the information be shared;
* When the disclosure is necessary to prevent fraud;
* When the disclosure is necessary for Corporate Issuer Solutions to perform
its duties;
* When providing information necessary for third parties to perform services on
behalf of Corporate Issuer Solutions; and
* When the disclosure is required by law.
IMPORTANT INFORMATION FOR EEA, UNITED KINGDOM AND SWISS RESIDENTS
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
Suite 300
Lake Success, New York 11042
USA
Email: privacy@broadridge.com
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:
* To fulfill a contract with you or our client; and
* With your or our client’s consent (where required and provided you have not
objected, as may be applicable).
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:
* protect you, us or others from threats (such as security threats or fraud);
* comply with the laws that are applicable to us around the world;
* enable or administer our business, such as for the provision of services to
our clients, quality control, consolidated reporting, and client service;
* market our products and services to existing and prospective clients;
* manage corporate transactions, such as mergers or acquisitions; and
* understand and improve our business or client relationships generally.
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:
* processing of customer data in accordance with our client contracts; and
* payment processing and financial account management, contract management,
website administration, business continuity and disaster recovery, security
and fraud prevention, corporate governance, reporting and legal compliance.
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:
* you generally have a right to know whether or not Broadridge maintains your
personal information. If we do have your personal information, we will
provide you with a copy (subject to the rights of others). If your
information is incorrect or incomplete, you have the right to ask us to
update it;
* you have the right to object to our processing of your personal information;
* you may also ask us to delete or restrict your personal information; and
* you may also have the right to data portability in some circumstances.
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 privacy@broadridge.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 privacy@broadridge.com 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 privacy@broadridge.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:
* we may share your personal information with our affiliates and subsidiaries;
and
* we may share your personal information with our vendors and subprocessors in
connection with providing contracted services and products.
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 Tool.
IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
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.
HOW TO CONTACT US AND OUR CHIEF PRIVACY OFFICER
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 privacy@broadridge.com. You can also reach us via mail at the postal address
provided above.
Broadridge Financial Solutions, Inc.
Attn: Chief Privacy Officer
5 Dakota Drive
Suite 300
Lake Success, New York 11042
USA
This Privacy Statement was last updated November 9, 2021.
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investing, corporate governance and communications to enable better financial
lives. We deliver technology-driven solutions that drive digital transformation
for our clients and help them get ahead of today’s challenges to capitalize on
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information. The information collected might relate to you, your preferences or
your device, and is used to make the site work as you expect it to and to
provide a more personalised web experience. You have choices about these
cookies. Click on the different category headings below to learn more and change
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or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.
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These cookies allow us to count visits and traffic sources so we can measure and
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These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant advertisements on other sites. They do not store directly personal
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be less targeted.
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