The following Privacy Policy governs the online information collection practices of Vinyl Equity(“Company,” "we" or "us"). It outlines the types of information that we gather about you while you are using our applications at vinylequity.com, transferge.com (the "Sites") and the ways in which we use this information. Vinyl Equity is a web-based SaaS transfer agent application and platform for publicly traded companies to manage their share registry, dividend plan, proxy voting and compliance. The application helps customer companies keep records of who owns their securities (e.g., shares, bonds, etc.). We also enable the investors in these companies who have created Vinyl Equity accounts to manage their investments via the application. Collectively, we refer to the customers and investors as “Users” of the web-services and product offerings (“Service(s)”) provided by Vinyl Equity. We process their data in accordance with the applicable laws and regulations following industry best practices.
1. Purpose and Scope
The Privacy Policy applies primarily to information that we collect online; however, it may apply to some of the data that you provide to us offline and/or through other means, as well (for example, via telephone, or through the mail).The Privacy Policy documents and describes the manner in which our organization collects information from all our Users of our Services. The use of information collected on behalf of our Users is governed primarily by our contract for the engagement with them and the privacy policies governing their organization. We are not accountable for the privacy policies and practices undertaken by our users or any other third parties. Some information is collected through the use of cookies, web beacons and tracking technologies. Please refer to the cookie policy for more details on the type of cookies being used.
2. How we collect data about you
We may collect different data from or about you depending on how you use the Sites. We receive personal information about you from third parties such as issuers, brokers, or other intermediaries.
2.1. Data provided by registered users
Account creation and login: When you create an account or login into your account, we collect personal information such as first name, last name, email address, phone number, date of birth, social security number, mailing address and proof of identity and address.
2.2. Data collected through automated means:
System data: Technical data about your computer or device, like device type, operation system and the IP address. This data helps us improve the delivery of our web pages and to measure traffic on the Site. The collection of data will also depend on the individual settings of your device and software. It is recommended to refer to the policies of your device manufacturer or software provider to learn about information they might share with us.
2.3. Data collected during transactions:
Transactional Data: On the basis of types of services requested, Vinyl Equity also collects information such as: If you have any questions about this Privacy Policy, you can contact us at privacy@vinylequity.com
- Type of service that has been requested
- Order details for such a request
- Payment & transaction information
- Date and time the service provided
3. The Types of Information We Collect and Store
We may collect personal and sensitive personal information about you and store this information in connection with the provision and fulfillment of our services to you. Personal information may include:
- First name and last name
- Email address
- Location
- IP Address
- Phone number(s)
- Date of birth
- Tax Identification Number (e.g. Social Security Number)
- Mailing address(es)
- Proof of identity and address (e.g. Driver's license, Passport, likeness/liveness)
- Securities transaction information and legal documents
- Banking information
4. How we use your personal information
The above personal information may be used for the following purposes:
- To respond to your requests;
- To manage our relationship with you;
- For internal record keeping as required legally for the purposes of acting as Transfer Agent for issuers;
- To provide you with authorization to login and use your user account;
- To verify your identity;To maintain correct and up-to-date information about you;
- To identify you as a contracting party;
- To improve our website;
- To enable automated handling of the subscriptions;
- To otherwise be able to provide the services to you
- To comply with our legal or statutory obligations.
5. Who has access to your data within our organization?
Within our organization, access to your data is limited to those persons who require access in order to provide you with the Products and Services, to contact you, and to respond to your inquiries and requests. Those staff members may be on teams such as: marketing, events, development, executive, customer support and other functions at Vinyl Equity. Employees only have access to data that is relevant to their team, on a ‘need to know’ basis. [should we make the teams more relevant to a transfer agent business - we shouldn't use shareholder data for marketing purposes unless they've consented to it]
6. Who do we share your data with outside our organization and why?
6.1. Processors
We may use service providers & third parties for operating and improving the Sites, to assist with certain functions, such as identity verification, payment processing, email transmission, data hosting, third-party solutions for marketing and analytics, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, through the execution of Data Processing Agreements or Addenda.
6.2. Authorities
We may access, preserve, and disclose information about you to third parties, including the content of messages if we believe disclosure is in accordance with or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Company or others.
6.3. Transfer of business
If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.
7. Why and for how long do we store information we collect from you
We retain certain information collected from you while you are a user of our application, and in certain cases where you have deleted your account, for the following reasons:
- So that we can authenticate your account you can avail of our products and services;
- To ensure that we do not communicate with you if you have asked us not to;
- To provide you with payments, if entitled;
- To better understand the traffic to our platform and application so that we can provide all members the best possible experience;
- To detect and prevent abuse of our platform, illegal activities and breaches of our Terms of Service
- To comply with applicable legal, tax or accounting requirements.
We retain user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates to, and the purposes for which we collected the data.
8. Security
We implement a variety of administrative, managerial, and technical security measures to help protect your personal information. Our Company has various internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online. Our employees are trained to understand and comply with these controls and we communicate our Privacy Policy practices and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information. We urge you to take every precaution protect your personal information while you are on the Internet.
9. Your rights under GDPR
You have certain rights if you are within the EU including:
- Right to access: This right allows you to obtain a copy of your personal data, as well as other supplementary information.
- Right to restrict processing: You have the right to restrict the processing of your personal data in certain circumstances.
- Right to rectification: You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Right to object to processing: The right to object allows you to stop or prevent us from processing your personal data. This right exists where we are relying on a legitimate interest as the legal basis for processing your Personal Data. You also have the right to object where we are processing your Personal data for direct marketing purposes.
Right to erasure: You have the right to ask us to delete or remove Personal data when the personal data is no longer necessary for the purpose which you originally collected or processed.To exercise your rights, you can contact us at privacy@vinylequity.com
10. Your Rights Under CCPA
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). Included in these rights are:
- Right to know: You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
- Right to deletion: You have the right to request deletion of personal information that we have collected about you where we are legally able to do so.
- Right to non-discrimination: If you choose to exercise any of your rights under CCPA, we will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
- Right to opt-out: You have the right to opt-out of the sale of your personal information. We do not sell personal information.
However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA. If you wish to opt-out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt out is specific to the browser you use. Yo u may need to opt out on every browser that you use.
To exercise any of these rights under CCPA, please email privacy@vinylequity.com. To know more about your rights and how to exercise them visit our Data Subject Request Policy.
11. Your Rights as a Resident of Other States with Additional Privacy Rights
You may have certain additional rights regarding your personal information. For our clients that meet the definition of a business or data controller under these relevant state privacy regulations, Vinyl Equity 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; delete your personal information; restrict our use of your personal information; correct your personal information, and opt-out from the sale of your personal information (if applicable).
12. Our policy concerning children and their data
Our application and platform are NOT directed to children under the age of sixteen and we do not knowingly collect personally identifiable information from children or distribute such information to third parties. We screen users who wish to provide personal information in order to prevent children from providing such information. If we become aware that we have inadvertently received personally identifiable information from a child, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children.
13. Links to other sites
Our application and platform may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.Third parties are under no obligation to comply with this Privacy Policy with respect to Personal Data that you provide directly to those third parties or that those third parties collect for themselves. We do not control the third-party sites that may be accessible through our Services. Thus, this Privacy Policy does not apply to information you provide to third-party sites or gathered by the third parties that operate them.
14. Changes to this policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. If we make any material changes to the Policy, we will notify you via email, through a notification posted on the Services, or as required by applicable law. You can see when the Policy was last updated by checking the date at the bottom of this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from when they are posted on this page.
CONTACT US
If you have any questions about this Privacy Policy, you can contact us at privacy@vinylequity.com
Modern Transfer Agency