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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., Access Data Corp. 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/.

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.com and 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 corporations or other business entities (the “Business Owner” of the website). On these hosted sites, we also collect sensitive personal information that you provide, which for some services may include 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 that you provide 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.

Cookies and Other Data Collection Technologies

When you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. We do not, however, use tracking or cookie technology on pages of our websites that provide notice and access hosting services to public companies.

When you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about the privacy settings that may be available.

We may also use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. We use Flash cookies for security purposes and to help remember settings and preferences. We do not use Flash cookies or similar technologies for behavioral or interest-based advertising purposes. To manage Flash cookies, please see Adobe’s website at http://kb2.adobe.com/cps/526/52697ee8.html or visit www.adobe.com.

In connection with Broadridge marketing efforts, we may use pixel tags and web beacons. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions. Information collected using these technologies in our e-mails may be associated with the recipient’s e-mail address.

We collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to Broadridge and the website you visit after you leave our site.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Statement applies to the information when we associate it with your Personal Information.

On some of our sites, such as www.broadridge.com and Advanced Annual Meeting Solutions’ websites (the Shareholder Forum and Virtual Shareholder Meeting, which may be customized for the Business Owner) Broadridge directly or through third parties uses Google Analytics to provide it with information about the use of its websites. Google Analytics is a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using the Broadridge websites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

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 the personal information you provide on 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 info@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 on any of our websites 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 relating to any of the services requested through our websites. Please send requests to clientservices@investordelivery.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 may maintain some or all 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 to provide the services or 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 March 15, 2012.