Privacy Policy

*Last Modified: May 17, 2018


Introduction
American Stock Transfer & Trust Company, LLC and its affiliates (collectively, “AST”, “we”, “us” or the “Company”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (this “Policy”). Your privacy is important to AST and we go to great lengths to protect it.

This Policy describes the types of personal information we may collect from you or that you may provide to us anytime you are in contact with AST, including when you visit AST’s websites (the “Websites”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it.

Children Under the Age of 13
AST’s services and the Websites are not intended for children under 13 years of age. No one under age 13 may provide any personal information to AST, and AST will not knowingly collect personal information from children under 13. If you are under 13, do not provide any information about yourself to us (including through our Websites by using any of its features or registering on our Websites), including, without limitation, your name, address, social security number or tax identification number, 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 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@astfinancial.com.

Information We Collect About You and How We Collect It
Personal information means any information that is about you or which can help identify you. We may collect several types of personal information about you, including information:

  • By which you may be personally identified, such as name, mailing address, e-mail address, telephone, fax or mobile number, social security number or tax identification number, account number, securities or other asset ownership information; and
  • About your internet connection, the equipment you use to access our Websites and usage details.

We may collect this information in a number of different ways. We collect this information directly from you when you provide it to us, automatically as you navigate through the Websites, and from third parties in the performance of our services.

We do not collect or process any personal information in certain special categories, such as data that discloses racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

Information You Provide to Us
We collect the personal information that you choose to provide to us, including through any letter, telephone, email or any other means of electronic or personal communication. Depending on the reason you are contacting us, the personal information we collect may include your name, date of birth, social security number or tax identification number, address, phone number, email address, employment details, and banking information.

The information we collect on or through the Websites may include:

  • Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Websites.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Websites and of the execution of your instructions. You may be required to provide financial information before performing certain transactions through our Websites.
  • Your search queries on the Websites.


Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites; and
  • Information about your computer or other device you use to visit our Websites and your internet connection, including your IP address, operating system, browser type and version, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.
  • Web Beacons. Pages of our Websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages band for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Web Analytic Tools. Our Websites may use Google Analytics or similar web analytics tools that help website owners analyze the traffic to their websites. By using Google Analytics, the Company may be able to view a variety of reports about how users interact with the Websites, which can be used to improve your user experience and the overall quality of the Websites.


Information We Collect from Third Parties
We may also collect your personal information from third parties in the course of performing our services. For example, companies that engage us for our services may provide us with information relating to their shareholders, such as name, date of birth, social security number or tax identification number, address, phone number, employment details, and other personal information.

How We Use Your Personal Information
We use personal information that we collect about you or that you provide to us, including any personal information:

  • To respond to your inquiries and fulfill your requests.
  • To provide services to you and to our issuer clients.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To fulfill any other purpose for which you provide it.
  • To present our Websites and its contents to you.
  • To inform you about information regarding the Websites, products or services for which you apply or may be interested in applying for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information.
  • To verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of account and personal information.
  • To allow you to participate in interactive features on our Websites, including surveys and other forms of market research.
  • To help us to improve our Websites and to deliver a better and more useful experience to our customers and to understand which parts of our Websites, products, and services are of most interest.
  • For risk control, fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements.
  • To deliver marketing communications that we believe may be of interest to you, including ads or offers tailored to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To comply with a legal obligation or to carry out a legitimate interest that we or a third party may have.
  • In any other way we may describe when you provide the information.


When We Share Your Personal Information
Please see the Privacy Notice for information on how personal information may be shared with third parties. Additionally, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

How Long We Store Your Personal Information
We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your personal information, we will consider (a) the amount, nature, and sensitivity of such information, (b) the potential risk of harm from unauthorized use or disclosure of such information, (c) the purposes for which we process such information and whether we can achieve those purposes through other means, and (d) the applicable legal, regulatory, accounting or reporting requirements.

Upon expiration of the applicable retention period, we will securely destroy your personal information in accordance with applicable law and regulation.

How You Can Access and Update Your Personal Information
You may request a copy of the personal information we hold about you by contacting us. There may be a small fee for us to respond to your request. You may also review and change your personal information by logging into the Websites and visiting your account profile page.

Data Security
We have implemented measures designed to secure, to the best of our ability, your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

Changes to the Policy
It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Websites. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Websites and this Policy to check for any changes.

Contact Information
To ask questions or comment about this Policy and our privacy practices, contact us by email at privacy@astfinancial.com.