Last revised Dec 31, 2020

Q4 Inc. and its affiliates (collectively, “Q4,” “we,” “us,” or “our”) respects your privacy and is committed to protecting any data it collects about you that can be used to personally identify or contact you (your, “Personal Information,” “Personal Data,” or “Data”). By using or accessing our Products and Services, you accept the practices and policies outlined below, and you consent that we will collect, use and share your information as described in this Privacy Policy.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we collect as a data controller and that we process as a data processor when a User accesses or uses our Products or Services. For the purposes of this Privacy Policy, a User shall be defined as anyone who uses or access the Q4 Products or Services .

This Privacy Policy does not apply to anonymised data, as it cannot be used to identify a natural person. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data Example Categories of Third Parties With Whom We Share this Personal Data, if Applicable.
Contact/Profile Data
  • First and last name
  • Email
  • Phone number
  • Corporate Issuers and other investor relations professionals
Device/IP Data
  • IP address
  • Domain server
  • Type of device/browser used to access the Products/Services
  • N/A
Professional or Employment Related Data
  • Job Title
  • Current Employer
  • Location
  • Industry expertise/coverage
  • Corporate issuers and other investor relations professionals
Analytics
  • Statistics associated with interactions between device/browser and the Products and Services
  • N/A
Inferences Drawn from Other Personal Data Collected
  • Profiles reflecting user attributes
  • Profiles reflecting user behaviour
  • N/A

Sources of Personal Data

We collect Personal Data about you from the following sources:

You

  • When you provide such information directly to us.
  • When you consent to provide such information as part of accessing or using our Products or Services.
  • When you contact us.

Public Records

  • Public sites that may contain publicly accessible information.

Third Parties (Service providers to Q4)

  • Third parties may help us provide the Products or Services.
  • Third parties may provide us with data that we make available through our Products or Services.

Our Commercial or Business Purposes for Collecting Personal Data

Providing connection and access to investor relation and asset management professionals through our database

  • Allowing Users to search our database for investment professionals or corporate issuers in order to make accurate and timely investment decisions.
  • Providing users with the ability to track and analyze trends in select stock performance, shareholder movement, and investment decisions of asset management firms.
  • Improving the quality and accuracy of our database in order to provide the best possible Products and Services.

Meeting Legal Requirements and Enforcing Legal Terms

  • Fulfilling our legal obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Q4 or another party.
  • Enforcing agreements with our customers and resolving disputes.
  • Responding to claims that any posting or other content violates third-party rights.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We disclose your Personal Data to the parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers who help us provide the Products and Services or perform business functions:

  • Hosting, technology and communication providers.
  • Security and fraud prevention providers
  • Analytics providers

Parties You Authorize, Access or Authenticate

  • Third parties you access through the Products or Services
  • Other users.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Products and Services and promote our business, provided that we will not share such data in a manner that could identify you.

Cookies and Web Beacons

Cookies are bits of electronic information that can be transferred to your computer or other electronic device to uniquely identify your browser. When you use the Services, we may place one or more cookies on your computer or other electronic device. We may use cookies to connect your activity on the Services with other information we store about you in your account profile or your prior interactions on the Services to, for example, store your preferences. The use of cookies helps us improve the quality of the Services to you, by identifying information which is most interesting to you, tracking trends, session token or storing information you may want to retrieve on a regular basis. At any time, you may adjust the settings on your browser to refuse cookies according to the instructions related to your browser. However, if you choose to disable cookies, many of the features and Services will not operate properly. Also, the pages on the Services may include web beacons or pixels, which are electronic files to count users who have visited that page, track activity over time and across different Websites, identify certain cookies on the computer or other electronic devices accessing that page, or collect other related information. This information may be associated with your unique browser, device identifier, or Internet Protocol address.

3rd Party Cookies and Web Beacons

We have implemented Google Analytics and impression reporting for our client sites, which tracks and manages cookie information so that we can provide you with site analytics data through Q4 Products. This information is not used for advertising purposes.

International Transfer of Personal Information

With respect to European Data Subjects, Q4 and its service providers may store, transfer or process information outside of the E.U. Where this is required, Q4 will take certain measures to protect your Personal Information, including having appropriate agreements in place with service providers and requiring that any service providers agree to our Standard Contractual Clauses within the applicable Data Processing Addendum.

Data Subjects Rights in Relation to Use of Personal Information

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Subjects have the right to access, rectify or delete any Personal Information that we hold under European data protection legislation. You also have the right to portability and to object to the use of your Personal Information. If you wish to exercise any of these rights, please send an email to privacy@q4inc.com.

Storage, Security and Retention of Information

You acknowledge that Personal Information will be processed and stored by Q4 in databases hosted in the United States or Europe. Q4 has taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. We protect your Personal Information by maintaining a strong security standard in compliance with applicable laws and regulations. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting Personal Information.

We will retain your Personal Information for as long as you have an active account, as needed to provide you with the Services, to comply with our legal and regulatory process and to enforce this Privacy Policy. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Q4 has established internal policies for the deletion of Personal Data from customer accounts following termination of a customer’s subscription to the Service.

Children Under the Age of 13

Q4 will not knowingly collect Personal Information from any person under the age of 13.

Other Privacy Rights Laws and Regulations

California Resident Rights

European Union Data Subject Rights

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Q4 website, by sending you an email or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please contact us at:

California Resident Rights

Last revised Dec 31, 2020

This Privacy Notice for California residents and addresses the requirements of the California Consumer Privacy Act of 2018 (“CCPA”). Defined terms in the CCPA have the same meaning in this statement.

Information Collected

Q4 collects information pursuant to our Privacy Policy. The CCPA identifies categories of personal information that may be collected. The table set forth in our Privacy Policy indicates whether Q4 has collected such personal information in the last 12 months, the source of that information, and whether it has been shared with a third party for a business purpose in the last 12 months:

Q4’s Use of Your Personal Information

Personal information collected from you may be used for one or more of the business purposes set forth in our Privacy Policy

California Residents’ Rights under the CCPA

You have specific rights regarding how your personal data is collected and used.

You have the right to request that Q4 disclose our collection and use of your personal information during the past 12 months, specifically:

  • Categories of personal information collected;
  • Sourced of personal information collected;
  • Our business purpose for collecting (or selling) that personal information;
  • Categories of third parties with whom we share your personal information;
  • Categories of personal information sold or disclosed to third parties.

You have the right to request a copy of the personal information collected prior to your request in the past 12 months;
You have the right to request deletion of that information (with exceptions noted by law);
You have the right to request that your personal information not be sold to third parties, if applicable; and
You have the right not to be discriminated against because you exercised these rights.

We will respond to your verifiable request to disclose and or delete your personal information within 45 days, providing you with an electronic copy of your information; however, if we up to an additional 90 days as permitted under the CCPA to respond, we will inform you within 45 days of your request.

In the event you request deletion, Q4 will be unable to do so, as permitted by the CCPA, in event the personal information is necessary to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between Q4 and you;
  • Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with a legal obligation;
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided information.

How to Contact Q4 to Exercise Your Rights

You can submit your request for disclosure, copies or deletions of your personal information to Q4 by contacting us (or contact us with your questions regarding our collection, use and sharing of your personal information):

The CCPA restricts you to two verifiable requests within a 12-month period. Only you or a person registered with the California Secret of State that you authorize to act on your behalf may make a verifiable request regarding your personal information. Q4 cannot respond to a request if we are unable to verify your identity or authority to make the request on behalf of another. Please provide information sufficient to confirm your identify or your authority to make the request on behalf of another, and describe your request with sufficient detail that allows us to understand and respond to your request. We will endeavor to respond to your request within 45 days of receipt. If more time is required (up to 90 days), we will inform you of the reason and extension of time required. There is no fee charged for processing your request.

Reservation of Rights

Q4 reserves it rights with regard to any verifiable request, its evaluation of what is necessary to comply with the CCPA, and to amend this notice at any time within Q4’s discretion.

European Union Data Subject Rights

Last revised Dec 31, 2020

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Q4 will be the controller of your Personal Data collected and processed in connection with your use of the Services. Note that we may also process Personal Data of our customers’ end users in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether the following applies to you, contact us at privacy@q4inc.com

Personal Data We Collect

The “Categories of Personal Data We Collect” section in our Privacy Policy details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section in our Privacy Policy explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
    • Profile or Contact Data
    • Commercial Data
    • Device/IP Data
    • Web Analytics
    • Social Network Data
    • Geolocation Data
    • Inferences Drawn From Other Personal Data Collected
    • Other Identifying Information that You Voluntarily Choose to Provide
  • Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
    • Profile or Contact Data
    • Commercial Data
    • Device/IP Data
    • Web Analytics
    • Social Network Data
    • Professional or Employment-Related Data
    • Geolocation Data
    • Inferences Drawn From Other Personal Data Collected
    • Other Identifying Information that You Voluntarily Choose to Provide
    • We may also de-identify or anonymize Personal Data to further our legitimate interests.
    • Examples of these legitimate interests include (as described in more detail above):
      • Providing, customizing and improving the Services.
      • Marketing the Services.
      • Corresponding with you.
      • Hiring and managing employees.
      • Meeting legal requirements and enforcing legal terms.
      • Completing corporate transactions.
  • Consent: In some cases, we process Personal Data based on the consent you grant to us at the time we collect such data.
  • Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section in our Privacy Policy details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@q4inc.com. In some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law. In those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. However, if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about Q4’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Q4 and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Q4 in the U.S. and will be hosted on U.S. servers, and you authorize Q4 to transfer, store and process your information to and in the U.S., and possibly other countries. We take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses.