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Privacy

Say Technologies LLC, ("Say", "we", "our", or "us") values your privacy. This Privacy Policy ("Policy") explains how we process personal information we collect about you through our website, online services, and when you otherwise interact with us, such as through our business relationship with broker-dealers and issuers, and through our customer support channel. These activities are collectively referred to as the "Services".

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Information You Provide Us We collect personal information you provide when you use our Services or otherwise engage or communicate with us as described below.

  • Shareholder Account Setup.

    When you log into the Shareholder Service, we may ask you for your email address and phone number. We will also ask for you to authorize access to your investment accounts through our third-party service provider. You may also provide additional profile information such as your name and information regarding your investments.

  • Shareholder's Submissions and Public Postings.

    We collect any information you submit, post, or otherwise make available on our Shareholder Service, including information about your investment accounts. For example, on the Shareholder Service we may allow you to create and interact with proposals about companies which you have investments with ("Listed Companies"), or to submit input regarding them, for example when they request investor feedback on management proposals, strategic plans or other issues. Please be aware that information you post with respect to Listed Companies may be accessible to other users and we are not responsible for the manner in which other users use or disclose this information.

  • Votes.

    We collect any voting instructions you submit to us, which we provide to tabulators and other third parties as required by applicable law.

  • Delivery Preferences and Beneficial Owner Status.

    We collect any information you submit to us regarding your (i) shareholder materials delivery preferences, and/or (ii) your status as an objecting or non-objecting beneficial owner.

  • Communications.

    If you contact us directly, we may receive additional information about you. For example, when you email our Customer Support Team or sign up to receive updates regarding new products and/or services, we will receive your email address, the contents of a message and any attachments that you may send to us.

  • Information about Partners and Vendors.

    We may receive contact details of Partners' and vendors' employees as provided by them in furtherance of the relevant Partner or vendor relationship, such as first and last name, email address, phone number, title and department.

Information Provided by Third Parties
  • Information About Shareholders' Holdings.

    When you link your investment accounts to the Shareholder Service, we obtain information regarding your investments, trade history, position size, name and contact information. We store this data and use it to operate and improve our Services and provide you with opportunities with engagement. We work with Plaid to access this information for the purpose of establishing and maintaining your account on the Shareholder Service. We will retrieve this information when the connection is first set up and on an ongoing basis after that, for as long as you continue to use the Shareholder Service.

  • Information Provided by Partners.

    We offer services to our Partners, which may also involve processing shareholders' personal information (our "Partner Activities"). In this context, we allow Partners to manage the distribution of shareholder materials, including proxy materials, to shareholders. When we process personal information on behalf of our Partners in the context of our Partner Activities, these Partners determine why and how the personal information is processed. If you are a customer of one of our Partners and receive shareholder materials from Say, you can learn more about the Partners' privacy practices practices by viewing their privacy policies.

Information We Collect Automatically

We also collect certain information about you automatically when you use our Services, as described below.

  • Information Collected via Cookies and Similar Technologies.

    When you use our Services, we may collect information about you through automated means, such as cookies, web beacons, and web server logs. The information includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Services. We may use this information to ensure our Services function properly, to determine how many users have provided comments or opened messages, to analyze Shareholders' and website/app visitors' preferences, to prepare reports for our Partners, or to prevent fraud. For example, we work with analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about your use of our Services and report on activities and trends. You can learn about Google's practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

  • Information We Collect on Behalf of our Partners

    We also process personal information on behalf of our Partners in the context of our Partner Activities. For example, we may receive personal information relating to shareholders from Partners themselves, such as name, contact information, as well as information regarding the shareholders' position(s) in public companies. We may also collect information directly from shareholders on our Partners' behalf, such as contact and delivery preferences and, to the extent applicable, input solicited by the public companies they are invested in, including votes on matters at annual or special meetings of Shareholders. We may also receive personal information about shareholders from any service provider other than Say who previously provided such services to Partners, such as address information and delivery and contact preferences.

HOW WE USE YOUR INFORMATION

We may use the personal information we collect:

  • To provide you with the Shareholder Service, in particular to facilitate your interactions with and use of our online and app-based shareholder communication and engagement platform and to deliver shareholder materials to you.

  • To operate, maintain, enhance and provide features of our Services, to provide services and information that you request, to respond to comments and questions, and otherwise to provide you customer support.

  • To manage our business relationships with our Partners and vendors.

  • To understand and analyze trends, shareholders' and website/app visitors' preferences and behavior, and financial insights to improve our Services, to develop new products, services, features and functionality, and to personalize your experience when interacting with our Services.

  • To contact you for administrative or informational purposes, including by providing customer service or sending communications.

  • For marketing purposes, such as developing and providing promotional and advertising materials .

  • To de-identify and/or aggregate data collected through our Services to prepare aggregated reports.

  • For our business purposes, such as audits, security, compliance with applicable laws and regulations, fraud monitoring and prevention, and to enforce our Terms of Service and other legal rights.

If you are located in the European Economic Area, we only process your personal information based on a valid legal ground, including when:

  • You have consented to the use of your personal information;

  • We need your personal information to provide you with the Services, including for account registration or to respond to your inquiries;

  • We have a legal obligation to use your personal information;

  • We or a third party, have a legitimate interest in using your personal information. - We only rely on our or a third party's legitimate interests to process your personal information when these interests are not overridden by your rights and interests.

DISCLOSURES OF YOUR INFORMATION

We disclose personal information that we collect through our Services to third parties in the following circumstances:

  • To Listed Companies that you provide input about through the Shareholder Services.

  • To our Partners and other shareholders participating in the Shareholder Services.

  • To other shareholders or interested parties that are attempting to contact other shareholders, as permitted by applicable law.

  • To our third-party service providers who provide services such as website hosting, data analysis, customer service, email delivery, auditing, and other services (e.g., materials distribution and printing).

  • To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).

  • If required to do so by law or with the good faith belief that such action is appropriate under applicable law, to comply with legal process; to enforce our terms and conditions, to protect our rights, safety, and the rights of our affiliates, and the rights of others.

SECURITY

We use reasonable efforts to maintain the integrity and security of your personal information. Please be aware that no security measures are 100% secure, therefore we cannot guarantee absolute security. It is important that you maintain the security and control of your account credentials, and not share your password with anyone.

YOUR CONTROLS
  • Account profile. You may update, correct, or delete certain account profile information by contacting us at the contact information listed below.

  • Disabling certain data sharing. You may decline to share certain information with us. Please note that this may impact some of the features and functionality of our Shareholder Service.

  • Cookie controls. Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again. You may also want to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of our Services.

If you are located in the European Economic Area ("EEA"), you may have the following additional rights:

  • Request access to and receive information about the personal information we maintain about you, update and correct inaccuracies in your personal information, restrict or object to the processing of your personal information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

  • Withdraw any consent you previously provided to us regarding the processing of your personal information at any time. We will apply your preferences going forward, but this will not affect the lawfulness of the processing before your consent withdrawal.

These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us at contact information provided below.

CHILDREN

Our Services are not intended for children under the age of 18 and we do not knowingly collect information from children under the age of 18. In the event we learn that we have inadvertently collected personal information from a child under age 18, we will take steps to delete that information. If you become aware that we have any information from a child under 18, please contact us at the contact information listed below.

INTERNATIONAL DATA TRANSFERS

Say uses servers hosted in the United States. Please note that we may be transferring your information outside of your region for storage and processing in the United States and around the globe. We may also transfer your personal information to countries for which adequacy decisions have been issued and may use contractual protections for the transfer of personal information, as necessary. If you are located in the European Economic Area (“EEA”), you may contact us as specified below to obtain a copy of the safeguards we use when we transfer personal information outside of the EEA.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy will evolve with time, and when we update it, we will revise the Effective Date above and post the new Policy. If we make material changes, we may notify you through our Shareholder Service or by sending you an email or other communication. We encourage you to read this Policy periodically to stay up-to-date about our privacy practices.

Contact Us

To report an incident or if you have any questions about these terms please contact dataprivacy@saytechnologies.com or by writing us at:

85 Willow RdMenlo Park, CA 94025