Privacy Policy

Effective as of May 23, 2023. 

This Privacy Policy describes how the Shareholder Commons (“TSC,” “we“, “us” or “our“) handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website and social media channels, as well as through social media, our marketing activities, our live events and other activities described in this Privacy Policy (collectively, the “Service“).

TSC is a U.S.-based non-profit organization with a mission to align the incentives of diversified investors with system well-being, thereby protecting the people and planet that undergird our economy. As such, TSC engages a wide range of actors in the investment ecosystem to support collective action among investors and to drive changes in the cultural, policy, and regulatory environments that surrounds them.

TSC may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

Index

• Personal Information we collect
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfer
• Children
• Changes to this Privacy Policy
• How to contact us
• Notice to European users

Personal information we collect

Information you provide to us. Personal information you may provide to us through the service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name and phone number.
• Transactional data relating to or needed to process your donations on or through the Service, including transaction history.
• Financial and payment data needed to complete your donations, such as your bank account number, payment card information, or stock information (if making a stock donation).
• Demographic information, such as your city, state, country of residence, postal code, and age.
• Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third party sources. We may combines personal information we recieve from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms and other publicly available sources.
• Our affiliate partners, such as our publishers, influencers, and promoters, who participate in our paid affiliate programs.
• Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our cookie notice.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to:

• maintain clear contact information for future one-on-one communication with TSC about matters related to our mission;
• promote a specific initiative (like a tender or letter) to which you have signed on;
• provide, operate and improve the Service;
• facilitate your invitations to contacts who you want to invite to the Service;
• enable security features of the Service;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events in which you participate;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We, our service providers may collect and use your personal information for marketing purposes:

• Direct marketing. We may send you direct marketing communications, such as our newsletter, or contact you about future engagement or advocacy opportunities that we believe may be of interest to you. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors. Certain payment and financial data you use to make a donation on the Service is collected and processed directly by our payment processors, such as PayPal (such as when you donate with a credit card or through Pay Pal) or Stock Donator (such as when you donate stock contributions). PayPal may use your payment data in accordance with its privacy policy, https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, TSC or our affiliates (including, in connection with a bankruptcy or similar proceedings)

Your Choices

In this section, we describe the rights and choices available to all users. Users who are located in the United Kingdom, Switzerland, and the European Economic Area can find additional information about their rights in the Notice to European Users.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other Sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

For details on how we transfer the personal information of individuals in the European Economic Area, the United Kingdom, or Switzerland, please see the Notice to European Users.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

• Email: info@theshareholdercommons.com
• Mail: PO Box 1268, Northampton, MA 01061
• Phone: +1(302)485-0497

Notice to european users

The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom, Switzerland, and the European Economic Area (hereafter collectively referred to as “Europe”).

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. What is “personal data”? Essentially, personal data is information about an individual from which that individual is either directly identified or can be identified. It does not include ‘anonymous data’ (i.e., information where the identity of the relevant individual has been permanently removed and that individual is no longer identified or identifiable).

Controller. The Shareholder Commons is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. (i.e., the EU GDPR and the UK GDPR (as and where applicable, the “GDPR”)). See the How to contact us section above for contact details.

EU/UK representatives. Our data protection representative in the European Union/United Kingdom is DataRep

Legal bases for processing. We use your personal information for the purposes listed below. In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing the personal information described in this Privacy Policy are set out below.

Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention. We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. In the context of initiatives, we will retain your information for as long as the initiative is underway and still relevant to TSC’s work to foster beta stewardship but will not use it for means not outlined in this policy.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us.
If you provide us with any sensitive personal information to us when you use the services, we will ask that you consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

Your rights. European data protection laws give you certain rights regarding your personal information in the circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be described to you, if applicable, at the time of your request.
• Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.
• Object. Object to our processing of your personal information where we are relying on Legitimate Interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
• Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

You may submit these requests via our email or postal address provided in the How to contact us section. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction:

• For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en
• For users in the United Kingdom – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/

Cross-border data transfer. We may share your personal information with third parties who are based outside Europe.

We endeavor to ensure that people to whom we provide your personal information hold it subject to the standards required by European data protection legislation. So, whenever we transfer your personal information to a third party out of Europe, we try to ensure a similar degree of protection is afforded to it by making sure at least one of the following mechanisms is implemented:

• Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal data by the European Commission or UK Government (as and where applicable) from time to time.
• Transfers to territories without an adequacy decision.
  • We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for Personal Data by the European Commission or UK Government (as and where applicable).
  • What this means is that the relevant authority(ies) have not adopted an ‘adequacy decision’ to confirm that the relevant laws and practices in that country or territory are sufficient to ensure an adequate level of protection for personal data to the standards required by the GDPR – for example, there is currently no such decision in respect of the United States.
  • However, in these cases:
    • we may use specific appropriate safeguards approved by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable), which are designed to give personal information the same protection it has in Europe – for example, requiring the recipient of personal information to enter into the relevant form of the so-called ‘Standard Contractual Clauses’ issued or approved from time to time; or
    • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.