Date of most recent update: December 14, 2020

1. INTRODUCTION AND SCOPE OF POLICY

This Shareowner Services Online and Mobile Privacy Policy (“Policy”) applies to your interaction with Shareowner Services or any of its affiliates (collectively, “Shareowner Services,” “we,” “us,” “our”), at any online or mobile site or application that we own and control (“Site”), unless a different online and/or mobile policy is posted at a particular site, or is made available to you and by its terms supplants this Policy. Other privacy policies may also apply in addition to the terms of this Policy. This Policy also explains certain data use and data protection functionalities and practices of our email, online ads, such as banner ads, on third party sites. Please note that where we have another type of presence on a site owned by a third party, such as a page or handle on a social media site, that third party’s privacy policy and terms of use, rather than this Policy, will govern, unless specifically stated otherwise.

2. AGREEMENT TO POLICY

By using a Site or interacting with a Shareowner Services page or account on a third party site, you consent to this Policy, including your consent to our use and disclosure of information about you in the manner described in this Policy.

3. GATHERING, USING, AND SHARING INFORMATION

Types of Information

You may interact with us in a variety of ways online, including through a mobile device, if that functionality is offered. We may offer sites or applications that permit browsing and do not require registration. We may also offer the ability to access your accounts online. Information that we may collect about you through online interaction includes information that you input, such as your name, address, email address, other contact information; data resulting from your activity, such as transaction information; and location information. We may also gather additional information such as the type of device and browser you are using, the IP address of your device, information about your device’s operating system, and additional information associated with your device. We may also gather information collected through cookies, tags, and other technologies, as described further below.

If you are a resident of the State of California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”), EQ hereby advises you of the following:

1. We collect identifying information about you, including your name, address, Tax Identification Number (Social Security Number), and possibly your telephone number and information about your computer usage, including your IP address.
2. We collect this information in order to enable us to provide services to you. We do not sell your information to any third parties.
3. This information may be shared with tax authorities, print and mail vendors, entities who perform services directly related to our services as the registrar and transfer agent for the securities you own, and the issuers whose securities you may own.
4. You have the right to contact us and request copies of the information we hold about you, and to request that this information, if inaccurate, be corrected. We can be reached through US Mail, our telephone numbers associated with the securities you hold, or by sending a request through the Contact Us link at shareowneronline.com.
5. While the CCPA affords you the right to request that your information be deleted from our systems, because this information is needed to perform the services we carry out on behalf of you as a shareholder and the issuers whose securities you may own, we are unable to delete your data if requested.

If you have any questions about your rights under the CCPA, please contact us and we will endeavor to assist you.

About “Cookies”

Cookies are pieces of data stored on your device. Browser cookies are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server. Mobile applications may also use cookies.

We use cookies and information gathered through their use to make your experience with Shareowner Services and certain other sites richer and more personalized based on the products, services, or other interaction you have with us and other sites.

Other parties that may collect information about your web browsing behavior when you use our Site are generally limited to service providers who may only use any information collected to provide services and marketing for us and not to provide services or advertising for any other party. Note, however, that we may also provide certain widgets or tools on our sites, such as tools that allow web surfers to easily share information on another platform, such as a social media platform. At other times, information from a third party may be embedded on our site, such as a map or information streaming from another site, including communications streaming from a third party social media platform. These widgets, tools, and informational items often function through the use of third party cookies utilized by the third party site, such as the social media platform. You may wish to review information at third party sites, such as social media platforms where you have an account, to determine how these third parties treat data that they obtain through the use of cookies.

We also use cookies for purposes such as maintaining continuity during an online session; gathering data about the use of our site; monitoring online promotions; and anti-fraud and information security purposes.

Do You Have to Accept Cookies?

You may be able to set your browser to reject browser cookies. However, if you choose to reject cookies, you may not be able to access your accounts online with Shareowner Services. Therefore, if you set your browser options to disallow cookies, you may limit the functionality we can provide when you visit our Site. The latest versions of internet browsers provide cookie management tools, such as the ability to delete or reject cookies. We recommend that you refer to information supplied by browser providers for more specific information, including on how to use these tools.

Additional Cookies

Cookies is a term also used to describe other locally stored objects, such as cookies stored in an Adobe folder on your device. These cookies will not be deleted when you clear cookies from your browser. We may use this technology for purposes such as information security and fraud prevention. We do not use this technology for online behavioral advertising purposes. Please refer to information provided by Adobe for information on how to disable and control Flash objects. If you choose those options, you may limit the functionality we can provide when you visit our Site.

Additional Technologies

We may also use additional technologies such as pixel tags, web beacons, and clear GIFs, and may permit our third party service providers to use these technologies. We may use these technologies for purposes such as measuring the effectiveness of our communications and determining viewing and response rates.

Using Information

In addition to the uses described above, we use information for purposes as allowed by law such as: servicing; communicating with you; improving our Site, products, or services; legal compliance; risk control; information security; anti-fraud purposes; marketing or personalizing the presentation of our products and services to you; tracking website usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our sites; and we may also use read-receipt notifications in our email communications.

Sharing

We may share information with service providers or affiliates with whom we work, such as data processors and companies that help us provide products and services to you. When permitted or required by law, we may share information with additional third parties for purposes including response to legal process.

4. CHILDREN’S PRIVACY

From our web pages, we do not knowingly collect personal information from individuals under the age of 13 without obtaining verifiable consent from their parents.

For more information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov

5. POLICY UPDATES AND EFFECTIVE DATE

If we make updates to this Policy, we will update the Policy with the changes and revise the “date of most recent update” posted at the top of this Policy. Any updates to the Policy become effective when we post the updates on the Site. Your use of the Site following the update to the Policy means that you accept the updated Policy.

6. GENERAL DATA PROTECTION REGULATION (GDPR)

Effective May 25, 2018, the European Union adopted a regulation known as the General Data Protection Regulation (GDPR).

As a resident of the European Union, you are protected by the provisions of the GDPR. As an entity known as a Data Controller, the issuer of stock is subject to provisions of the GDPR regarding your personal data and information.

Please take time to review the Privacy Notice, which sets out your rights under the GDPR. If you have any questions, please select contact us online or send written inquiries to:

EQ Compliance Officer
275 Madison Ave, 34th Floor
New York, NY 10016