Computershare wants to make your online and mobile experiences satisfying and safe. We will safeguard the privacy and security of your personal information while providing a personalized service that meets your individual preference and needs. This privacy statement provides an overview of how we use your personal information, our privacy practices and your privacy rights.  At all times we comply with applicable laws and regulations governing the confidentiality and security of information we receive and maintain. The Privacy Policy below relates to how we use your personal information to provide the Investor Center service via multiple channels, such as the world-wide web, mobile application, microsites, digital transfer, and more. If you are resident of Canada, please refer to the Canada Privacy Code sections below for details of how your personal information is managed.

What personal information do we obtain about you; how do we obtain it and what do we use it for?

When we say personal information, we mean any information that is about you, or which can help identify you.

We may collect your personal information in several ways. You may provide personal data to us directly, or we may collect your personal data from third parties as set out in this notice.

We collect your personal information when you sign up to the Investor Center service, express an interest in obtaining information about us or our products and services, provide information or initiate transactions via the Investor Center service or otherwise contact us.

Personal information we will use includes your name, address, phone number, government-issued identifier (e.g. social security number in the US), photo, identity documentation, banking details, marketing preferences, date of birth, e-mail address, geo-location, IP address, and information relating to your current shareholdings.

We use government-issued identifiers and identity documentation for purposes including verifying your identity and to comply with relevant laws such as tax laws and anti-money-laundering laws. We may also receive personal information about you from a third party authorized by you, such as a company in which you directly own shares, your broker or another intermediary acting on your behalf. We may also receive personal information about you from third parties in connection with verification of your identity and services provided to our client.

In certain circumstances, you may choose to participate in online identity verification to securely establish your identity. In such cases, to verify your identity, Computershare as a service provider to its client, engages a sub-processor, Trulioo, to collect, generate, analyze, extract, and store facial scans and measurements from ID photos and selfie images you provide ("facial scans") to compare them to determine if they match. Facial scans might be considered biometric data or biometric identifiers (collectively, "biometric data") under certain laws. Trulioo generates and processes facial scans and does not provide, share, or disclose facial scans to Computershare or its client. Trulioo retains and automatically deletes facial scans within 24 hours of using them to verify your identity. Computershare will receive a copy of your ID and selfie image as part of the online identity verification process only where this ID verification relates to the processing of a share trade or transfer and shall retain such documents as required by applicable law, which is currently for 6 years.

In order to participate in online identity verification using ID documentation, you must provide your informed written consent to the collection, use, and storage of facial scans in connection with your use of your account to verify your identity.

When you visit our websites or open emails from us, we may collect information about your geo-location, IP address, website use and email viewing so we can secure and improve our services.

We collect and retain our system audit logs to protect and mitigate against fraud and other misuses of our services and to capture insights used for system analytics and improvement.

You may also provide personal information to us about other individuals, such as individuals you wish to transfer shares to or to add beneficiaries to your holdings. If you do this, you must ensure the other person agrees you may share their personal information with us and that we may use it in accordance with this privacy statement.

How do we use your personal information?

We use your personal information in the following ways:

  • To create and maintain your Investor Center user account.
  • To validate your identity and authenticate you.
  • To prevent fraud and financial crime.
  • To carry out your instructions in relation to the service we provide you.
  • To keep records of your holdings and any transactions that we facilitate on your behalf.
  • To respond to your queries and requests.
  • To provide you services and to enable us to provide services to our clients, who are companies that you may own shares in.
  • To provide you updates on changes to our policies or terms and conditions.
  • To help us improve our services.
  • To analyze how people use our websites.
  • For trend analysis to help us develop and improve our products and services.
  • To analyze use of the service and activities performed to provide you with correct information and offer you relevant services (where permitted).
  • To perform analysis of shareholdings and activities performed via Investor Center.
  • If you agree to update you on topics where you have requested this or contact you about other services and products, we think may interest you.
  • To comply with our legal and regulatory obligations.
  • To monitor the security and use of IT systems.
  • To deal with any complaints or legal claims.
  • To manage our business efficiently and properly, including managing our financial position, resources, the risks to which we are exposed and how we arrange our internal operations.
  • To determine when you have accessed email messages and web content provided by us.

What are our legal reasons for using your personal information?

Where we process your personal information, under some relevant privacy legislation we need to have a valid legal basis for doing so. In connection with the provision of the Investor Center service our legal bases are one or more of the following:

  • It is necessary for us to process your personal information for us to fulfil our obligations under the terms and conditions of our Investor Centre Agreement with you or to take steps at your request before entering a contract/ agreement with you.
  • It is necessary for us to comply with a legal obligation to which we are subject to.
  • You have given consent to processing for one or more specific purposes.
  • It is necessary for the purposes of legitimate interests pursued by us or by a third party, and those interests are not overridden by your interests or your fundamental rights and freedoms.
  • It is necessary for the performance of a task carried out in the public interest, for example some financial crime screening.

Who do we share your personal information with?

While providing services to you, we may share your personal information with:

  • Other Computershare Group companies
  • Non-Computershare companies to whom we outsource the delivery of some of our services e.g., identity verification
  • Non-Computershare companies who help us with administrative services, including printing, mailing and IT services
  • Secure information storage and destruction providers
  • External training providers
  • Companies you hold shares in 
  • Our legal or other professional advisors, including our auditors
  • Agencies or government authorities to comply with our legal or regulatory obligations

Where we share your personal information with third parties, all such parties will be obligated to maintain the confidentiality and security of your personal information and, except as may be required by law or governmental regulation, will be prohibited from further disclosing the information except in furtherance of the purposes for which it was disclosed, in which case such further disclosure will be subject to the same confidentiality and security obligations. We will not disclose your personal information to anyone outside these parties or sell to any parties for unsolicited marketing purposes. At your direction, we may share your information with third parties on a referral basis in connection with products and/or services not offered by Computershare.

Where is your personal information processed?

In the provision of the Investor Center service, your personal information is primarily processed and stored in the United States but may be transferred to, processed and stored in countries outside of the United States by Computershare's service providers, all in accordance with this Privacy Statement. As Computershare forms part of a global group of companies, we may also disclose your personal information to overseas entities within the Computershare Group who assist us in supplying our services including through data storage solutions, back-up services, telephony, printing, and IT support.

Where we send your personal information to another country, we will always ensure adequate measures are in place to safeguard it and to ensure you can exercise your privacy rights effectively.

How long do we keep your personal data for?

We keep your personal data for as long as we need to for the purposes for which it was collected or (if longer) for any period for which we are required to keep personal data to comply with our legal and regulatory requirements.

Your Rights

Depending on where you reside, privacy laws and regulations will specify the privacy rights you are afforded. Within this Privacy Statement, we have outlined rights that may apply to you. Should you wish to exercise any of your rights, utilize the link in the "Contact Us" section of this statement.

Accessing your information

You may ask for a copy of the personal data we hold about you by contacting us.

Correcting your information

We try to ensure all your personal data is accurate. If you find any inaccuracies or if your details change, please notify us promptly and we will correct them.

Erasing or restricting use of your information

You may ask us to erase or restrict the use of your personal data. If you do, we will comply with your request unless there is a legal reason for us not to (for example, if a law says we must retain records for a fixed period and to do so we must retain your personal data).

Do Not Sell

Under certain privacy laws and regulations, you may have the right to prohibit or restrict the processing or sale of personal information. If you wish to exercise this right, please contact us.

Withdrawing consent

Where the legal reason for us processing your personal data is that you have given your consent to that processing, you may withdraw your consent at any time. If you do so we will stop processing your personal data promptly.

Security Measures to Protect Personal Information

We employ appropriate administrative, technical and physical safeguards designed to protect your personal information and to ensure that it is not accessed by unauthorized persons. Information is encrypted for transfer wherever this is possible. Our security procedures may require you to provide proof of identification before we release personal information to you. This proof may be in addition to any password required to gain access to our online service. Multiple incorrect attempts or invalidation will result in a lockout from the information. We undergo periodic reviews of our security policies and procedures to help ensure that our systems are secure and protected.

You should never divulge your identification numbers, username, or password to anyone else. You should also never write your password down or store it on your computer and you should make sure you change it regularly.

Users will only receive text messages if they have provided an email address and/or mobile phone number and have consented to such a service. Text messages will be sent according to the terms of consent and any applicable terms and conditions.

Complaints

If you have any complaints about the way we use your personal information, please contact us and we will try to resolve the issue.

You may also have the right to complain to a data protection regulator or supervisory authority in your country. If you need more information about how to contact your local data protection regulatory or supervisory authority, please contact us.

How to Contact Us

If you have any questions about this statement, you may contact the Computershare US Privacy Office by email at USCSPrivacy@computershare.com or by mail to:
 
Computershare
150 Royall Street
Canton, MA 02021
Attention: US Privacy Office

Changes to Privacy Statement

Computershare may change this Privacy Statement from time to time. Each time you visit the website, please see the "Effective Date" to determine if it has been revised since the last time you entered the site. A "Revised" notation will serve as notice of a change.

Affiliated Companies Subject to this Privacy Statement

Computershare Inc. (inclusive of its Computershare Fund Services division)
Computershare Trust Company, N.A.
Computershare Entity Solutions

Effective January 17, 2020
Revised July 15, 2024
Revised February 3, 2025 

For Investor Centre users that reside in Canada

Computershare Canada Privacy Code:
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