Computershare wants to make your online and mobile experiences satisfying and safe. Our aim is to safeguard the privacy and security of your personal information while providing a personalized service that meets your individual preference and needs. At all times we comply with applicable laws and regulations governing the confidentiality and security of information we receive and maintain. We operate websites on behalf of several affiliated companies as listed at the end of this statement.

We process personal information pursuant to service agreements we have in place with our clients who have retained us to provide a variety of services on their behalf, including but not limited to transfer agency, plans administration, class action administration, corporate trust, corporate actions, and governance services.  The personal information that you or our clients provide to us is used to perform the various services that are described in each service agreement.

 

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

We collect your personal information when you register with us, express an interest in obtaining information about us or our products and services, participate in activities on our website or otherwise contact us. 

We use your personal information to provide you with notices about your account or subscription, including expiration and renewal notices, to carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

We also use your personal information when replying to you via the "Contact Us" page, and in any other way we may describe when you provide the information.

Generally, you control the amount and type of information you provide to us when using our websites. The personal information that we collect depends on the context of your interaction with Computershare's websites, the choices you make and the products and features you use.

Computershare collects personal information through our websites or text message service or receives personal information about you to enable us to provide our online and text message services to you and/or our clients. When we say personal information, we mean information that is about you or that can help identify you.  You may be asked to provide personal information such as your name, address, phone number, Social Security number, date of birth, employee identification number, e-mail address, bank account details, credit card and/or debit card information, proxy voting preferences or information on your current shareholdings. We may also collect your IP address.

We use Social Security numbers for many purposes, including to verify your identity and to comply with federal and state laws such as tax laws and anti-money-laundering laws. We also may receive personal information about you from a third party authorized by you, such as a company in which you directly own shares, your broker, a class action defendant 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.

We may share your information with Computershare-affiliated companies and with other service providers or state/governmental agencies as necessary to process a transaction or service your account or provide services to our clients.  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.  

Your personal information is processed and stored in the United States and may be transferred to, processed and stored in countries outside 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 and IT support. These entities are generally located in Canada, New Zealand, the United Kingdom and Australia. We may also disclose your personal information to other overseas affiliates and service providers who assist us in supplying our services or who perform functions on our behalf, all in accordance with this Privacy Statement.

 

Data Collection Technologies

In order to improve the quality of our website and services, we may from time to time send you what is known as a "cookie" as permitted by applicable laws and regulations. A cookie is a piece of text that a website transfers to your computer's hard drive. This cookie does not allow Computershare access to your hard drive, but it assists in identifying, for example, whether you have visited our website on a previous occasion. Only the site that posted the cookie can read it.

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 website. 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 website.

Please note that the websites to which this site may be linked may also make use of their own cookies to collect information from you. Most browsers will automatically accept a cookie, but it may be possible to set your browser to notify you prior to a cookie being sent at which point you can accept or reject it.

Additionally, we may collect information through the use of pixels, device IDs and similar technologies. A pixel is a line of code that is used by a website or third party to assign online activities to a computer or browser. The use of a pixel allows websites and us to record, for example, that a user has visited a particular website. Additional information from an earlier period or interaction may be included in the pixel. Currently, Computershare does not respond to "Do Not Track" signals from browsers.

If you access an online service maintained by Computershare or one of its subsidiaries (for example, Investor Center, which is maintained by Computershare Inc.) we may use a tool called "Google Analytics" which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use the information we get from Google Analytics to help us understand website traffic and webpage usage. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

We may share the information we collect via cookies and Google Analytics with our related entities within the Computershare Group including entities located outside of the United States who assist us in supplying our services including through data storage solutions, back-up services and IT support. These entities are generally located in Canada, New Zealand, the United Kingdom and Australia. We may also disclose it to others if required to do so by law.


Third Party Collection of Personal Information

Links to third party websites may be provided on this site for informational or other purposes. Computershare is not responsible for any personal information you may choose to submit to a third party website accessed from this site.

 

Security Precautions 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 will 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. f you have further questions about Identity Theft, you may find the US Federal Trade Commission website helpful.

Users will only receive text messages if they have provided a mobile phone number and have consented to such service.  Text messages will be sent in accordance with the terms of consent and any applicable terms and conditions.

 

Accessing and Updating Your Information

You may request a copy of the information that we hold about you by contacting us at the address below. There may be a small charge for this service unless prohibited by law. We also try to ensure that all information we hold about you is accurate. If you find any inaccuracies we will delete these or correct them promptly, subject to our policies and procedures. Communication with you may be impeded if the information we hold is inadequate or inaccurate.

 

Additional Information for California Consumers

In addition to the information provided above, if you are a current resident of California, you may have certain rights regarding your personal information. For our clients that meet the definition of a business under the California Consumer Privacy Act (CCPA), Computershare will assist those clients, to the extent possible, with the fulfillment of their obligations to respond to your requests. These may include, depending on the circumstance, the right to access the personal information that has been collected about you in the past twelve months; delete your personal information; restrict our use of your personal information; and opt-out from the sale of your personal information (if applicable). Computershare will not discriminate against consumers for exercising their rights under the CCPA. If you would like to discuss or exercise the rights you may have, feel free to contact us via email or mail as described in the section "How to Contact Us".

 

Additional Information for EU/EEA Residents

In addition to the information provided above, if you are a current resident of an EU/EEA country, you may have certain rights regarding your personal information.  Computershare will assist our data controller clients, to the extent possible, with the fulfillment of their obligations to respond to your requests.  These may include, depending on the circumstance, the right to access your personal information; rectify the personal information we hold about you; erase your personal information; restrict our use of your personal information; object to our use of your personal information; receive your personal information in a usable electronic format and transmit it to a third party (also known as the right of data portability); lodge a complaint with your local data protection authority; and withdraw any consent you have given to the uses of your personal information.  If you would like to discuss or exercise the rights you may have, feel free to contact us.

This Privacy Statement only applies to Computershare websites and does not apply to any websites from which you may have linked to this website or to any website to which you may link from this website.

 

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 to you that a change has been made.

 

Affiliated Companies Subject to this Privacy Statement

Computershare Inc. (inclusive of its Computershare Fund Services division)

Computershare Trust Company, N.A.

Computershare Governance Services Inc.

 

Effective January 17, 2020

Revised April 27, 2020