Privacy Statement

US – EU Safe Harbor Privacy Statement

For personal information that Broadridge Financial Solutions, Inc. and its affiliates Broadridge Investor Communications Solutions, Inc., Broadridge Securities Processing Solutions, Inc. and Broadridge Output Solutions, Inc. process for their clients from individuals in the European Economic Area, including Switzerland, Broadridge has committed to handling such personal information in accordance with the Safe Harbor Principles. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s Website at  http://www.export.gov/safeharbor/.

Privacy Protection Policy for Social Security Numbers

Broadridge collects Social Security numbers in the ordinary course of its business. Broadridge has implemented reasonable technical, physical and administrative safeguards to help protect the Social Security numbers from unlawful use and unauthorized disclosure. All Broadridge workers are required to follow these established procedures.
In particular:

  • Access to Social Security numbers is limited to those workers and service providers who have a need to access the information to perform tasks for Broadridge.
  • Social Security numbers are only disclosed to third parties in accordance with Broadridge’s established policies. Broadridge will only disclose Social Security numbers to those service providers, auditors, advisors, and/or successors in interest who are legally or contractually obligated to protect them or as required or permitted by law.

If you have any questions, please contact us at: privacy@broadridge.com.

Broadridge.com Web Site Privacy Statement

Broadridge believes that privacy is important to the success and use of the Internet. This statement describes the practices that Broadridge will follow with respect to the personal information it collects from users of www.broadridge.comand the other Broadridge websites or hosted websites that link to this Privacy Statement.

What is personal information?

“Personal information” is information that can be used to identify or contact you. Personal information includes your name, address, e-mail address, and phone number, as well as information you provide us about your interests and preferences.

In some cases, we operate or host websites for our customers, including banks, brokers, mutual funds and public companies (the “Business Owner” of the website). On these hosted sites, we also collect sensitive personal information that you provide, such as your account number and Social Security number, as well as information you provide when you access your account online or conduct transactions. All personal information and sensitive personal information collected via these hosted sites is considered “Confidential Information.”

How do we collect, use, and disclose personal information?

On Broadridge websites, we collect personal information from you so that we may provide you with, or contact you about, products, services and information, enhance your site visit or follow up with you after your visit.

If you provide personal information to us for our own use, we will use it to provide the products, services or information that you have requested and we may share it with our affiliates. We may also use your personal information for other internal business purposes, such as market research and legal compliance.

If you provide personal information or sensitive personal information to us via a hosted site, we treat that information as confidential and we only use it to perform the services requested by you or the Business Owner of the site. We may share your information with the Business Owner of the site, and also provide the Business Owner with information on your use of the website. If you have any questions regarding the Business owner’s use of your personal information, please contact the Business Owner directly. Broadridge may use aggregate information or statistics about the use of its sites and the products and services used through its sites, but these statistics would not include personal information.

We may share any personal information, even Confidential Information, with our vendors and other third parties who perform services for us, but we forbid these companies from using your personal information for their own purposes.

Please note that we may always disclose any information as required by law, when necessary for health or safety purposes, or when needed to protect our legal rights. For example, we may disclose information about you in response to a subpoena. We may also disclose information about you in connection with the transfer of assets of our business.

Finally, if you are located outside the United States, your personal information will be maintained by us in the U.S. We may transfer your personal information to countries outside your location or the U.S. However, we assure adequate protection for your personal information in compliance with all applicable laws.

What are cookies and how do we use them?

Some Broadridge websites utilize a standard technology called “cookies” to collect information about how our site is used. Cookies were designed to help a website operator determine that a particular computer had visited the site previously and thus save and remember any preferences that may have been set while the user was browsing the site. Cookies are small strings of text that web sites can send to your browser. Cookies cannot retrieve any other data from your hard drive or obtain your e-mail address.

If you are simply browsing a Broadridge informational site, a cookie may be used to identify your browser as one that has visited the site before.

If you are a registered user of a Broadridge website or a hosted website (and have a user ID and password), we may use cookies so that we can provide personalized information based on preferences you have indicated while using the website. Although you have the ability to modify your browser to either accept all cookies, notify you when a cookie is sent, or reject all cookies, it may not be possible to utilize Broadridge services which require registration if you reject cookies.

We do not, however, use tracking or cookie technology on pages of our websites that provide notice and access hosting services to public companies.

Do we collect your information for marketing communications?

Broadridge is a business to business service provider and does not market its services to individual consumers. However, Broadridge may use your personal information collected via Broadridge websites to contact you to respond to your inquiries or to contact your business about information relating to Broadridge’s or its affiliate’s products and services from time to time. Please email us at privacy@broadridge.com, if you do not want your information used for further marketing contact. Broadridge does not send Broadridge marketing communications to individuals who provide us with personal information via a hosted website for a Business Owner.

How can you correct, access, and update your information?

You may view and edit the personal information you have provided us by contacting us using the link provided on the website. Our customer support department can also reasonably assist you with other requests related to information about you that may be maintained by us. Please send requests to privacy@broadridge.com.

How do we protect your information?

We take reasonable steps to help prevent the loss, misuse and alteration of the information under our control. For example, we have implemented physical, logical, and administrative procedures to protect and secure the information we process and maintain. We also use encryption and firewall technologies to protect sensitive information during online transmissions.

How can you help protect your information?

If you have registered at a Broadridge website or a hosted website, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also remember to sign out of the registered site and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if others have access to your computer.

Can we change this Privacy Statement?

From time to time, we may want to use personal information in ways that are not anticipated by this Privacy Statement. If we make a material change to this Statement, we will post and highlight the policy changes. We will also notify you via email and give you a reasonable opportunity to opt-out of the new uses that would not be contemplated by the description of use on the related website and/or this Privacy Statement.

Other sites

Broadridge sites may contain links to other sites, including those of our business partners. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other sites.

Broadridge Corporate Issuer Solutions Information Security Program

Broadridge Corporate Issuer Solutions, a registered transfer agent, maintains an information security program to address the risk that customer information acquired in the course of its business is disclosed inadvertently without authorization, misused, altered, destroyed, or otherwise compromised. As part of this information security program, Corporate Issuer Solutions has designed and implemented safeguards to prevent such disclosure, misuse, alteration, destruction, or compromise and has implemented appropriate measures to oversee its service providers’ compliance with the program. Corporate Issuer Solutions also has adopted protocols for the proper disposal of any consumer report information acquired in the course of its business.

Corporate Issuer Solutions has implemented numerous physical, electronic, and procedural safeguards to prevent the unauthorized sharing of personal shareholder information, including the limiting of information to necessary employees and the encryption of sensitive website transmissions using Secure Sockets Layer (SSL) protection. Corporate Issuer Solutions maintains the following nonpublic information with respect to individual shareholders:

  • Shareholder name and address(es)
  • Shareholder taxpayer identification number
  • Information related to the shareholder’s share ownership, history, and/or dividends
  • In some cases, shareholder telephone numbers and/or e-mail addresses
  • In some cases, shareholder bank or brokerage account information
  • In some case, information from tax-related documents that is required to process tax reports and statements, stock transfers, and other securities transactions

Corporate Issuer Solutions maintains its records of securities and shareholders as an agent for the issuer of the security, and, accordingly, will provide the above-referenced information to the issuer or its designees. Corporate Issuer Solutions does not provide the aforementioned information about current or former shareholders to any third party except as permitted by law. Corporate Issuer Solutions will provide nonpublic, personal information:

  • When necessary to effect, administer, or enforce a transaction requested by the shareholder
  • When the shareholder requests or authorizes that the information be shared
  • When the disclosure is necessary to prevent fraud
  • When the disclosure is necessary for Corporate Issuer Solutions to perform its duties
  • When providing information necessary for third parties to perform services on behalf of Corporate Issuer Solutions
  • When the disclosure is required by law.

If you have questions or concerns regarding this statement, you should contact us at privacy@broadridge.com.

This Privacy Statement was last updated April 4, 2011.