Privacy Statement

Please carefully read the Privacy Statement below. Holdings information used solely on IVOX Glass Lewis platform is not shared outside of the EU.

Effective December 12, 2022

  1. Scope and Applicability of This Policy

Glass Lewis & Co., LLC and its affiliated and related companies are referred to collectively in this Privacy Statement as “Glass Lewis”. In addition to Glass, Lewis & Co., LLC, the affiliated and related entities of Glass Lewis are Glass Lewis Europe Limited, GL&M UK, Ltd., CGI Glass Lewis Pty. Ltd., IVOX Glass Lewis GmbH, Glass Lewis Japan GK, Glass Lewis Corporate LLC, and Proxinvest SAS. This Privacy Statement is issued on behalf of, and applicable to, all such entities so when we mention Glass Lewis, “we”, “us” or “our” in this Privacy Statement, we are referring to the relevant company within Glass Lewis that is responsible for processing your data and that acts as your data controller. In most cases your data controller will be the Glass Lewis entity which is referenced in our communications and interactions with you, including your agreement with Glass Lewis when you purchase a product or service from us. If you are not clear who your data controller is, in any given scenario, please let us know by contacting us using the details set out in the “How to Contact Us” section below.

Glass Lewis respects your privacy and is committed to protecting your Personal Information, as further described in Section 3, “Information We Collect”, below. This Privacy Statement will inform you as to how we collect, process and look after your Personal Information, when you interact with us via our website https://www.glasslewis.com/ (the “Glass Lewis Site”), the Glass Lewis Viewpoint online proxy voting platform accessible at https://viewpoint.glasslewis.com/, the Glass Lewis Governance Hub research portal accessible at https://www.glasslewis.net, the Glass Lewis Engagement Management Platform accessible at https://engagement.glasslewis.com/, any other website or platform under our control (collectively, “Our Platforms”), or by any other means (for example, when you complete application forms, complete a questionnaire or survey, sign up to receive Glass Lewis publications, or purchase any of our Services). Our Platforms and the products and services we offer may be collectively referred to in this Privacy Statement as the “Services”.

This Privacy Statement aims to inform you about your privacy rights and how the law may protect you in certain circumstances. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements, including the General Data Protection Regulation (“GDPR), the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act (“CPRA”), and other applicable privacy and data protection laws and regulations (collectively, the “Applicable Data Protection Laws”).

Unless otherwise set forth herein or agreed to between you and Glass Lewis, this Privacy Statement does not apply to information you submit to websites not controlled by Glass Lewis, even if linked to Our Platforms, including third party providers of products or services offered to users of the Services. It is your responsibility to read and understand the privacy policies applicable to such third-party sites and service providers.

  1. Agreement to Terms

If you do not agree with the terms of this Privacy Statement and our Terms of Use, then you should immediately discontinue use of the Services without providing us with any personal information.

  1. Information We Collect

We may collect the following categories of personal information (a) directly from you (such as when you create an account, contact us, complete a survey or registration form, or when you use any of the Services), (b) from third parties, (c) from the device and browser that you use to access the Services, (d) from publicly available information, and (e) from cookies and similar technologies.

Personal Information

We may collect your name, email address, account username and password, business address and phone number, employer’s name, and your title.

Financial and Transactional Information

We may collect payment details such as credit or debit card information, billing address, and purchase history.

User-Generated Content

We may collect information you post to Our Platforms, and if you complete a questionnaire or survey, we also collect your responses.

Inferences

We may also draw inferences from the information that we collect that reflect your preferences, characteristics, and interests.

Device Information

We may collect device information when you use our Services. Device information may include unique personal identifiers, online identifiers, IP address, geolocation information, browser type, device type, and access times.

Usage Data

We may collect information concerning your interaction with the Services, including when you access Our Platforms and your browsing activity on Our Platforms (such as which pages you visit, in what order, and for how long). This may also include “traffic data” or tracking information provided by Our Site’s host or similar providers (e.g., Google Analytics, HubSpot, WalkMe) that may be helpful for marketing purposes or for improving Our Platforms.

Marketing and Communications Data

We may collect your preferences in receiving marketing communications from us and our third-party providers and your communication preferences.

Aggregated Data

We may collect statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered “personal data” as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Services. If, however, we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Statement.

Personal Information collected from Third Party Sources

We collect personal information, including from publicly available information such as filings companies are required to make by law, voluntary filings or reports made available by companies, company websites, or investor relations materials, as well as from third parties authorized to provide us with such information, about individuals who sit on public company boards as directors or chairs, as well as other company representatives such as investor relations representatives or other similar positions. This information could include name, age, gender, race or ethnicity (if voluntarily disclosed by your company), current and past employment positions (including public companies where such persons may serve or have served as a director, officer, or other representative) compensation, and other related attributes.

Special Categories of Personal Information

Save as may be mentioned above, we do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

You are not required to provide all personal information identified in this Privacy Statement to use the Services or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, you may not be able register an account and we may not be able to respond to your requests.

  1. Cookies

We store certain information that gets collected automatically through Our Platforms via cookies and other similar technologies. A cookie is a small data file that a website that you visit transfers to your browser for identification purposes and may be stored on your hard drive. The vast majority of websites use cookies and a cookie file can contain information such as a user ID that Our Platforms use to track the pages you have visited. The only Personal Information a cookie can contain is information you supply yourself, and a cookie cannot read other data stored on your hard drive or cookie files created by other sites. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). Cookies on Our Platforms are generally divided into the following categories:

Strictly Necessary Cookies

These are required for the operation of Our Platforms and include, for example, cookies that enable you to log into password-protected portions of Our Platforms. These cookies are session cookies that are erased when you close your browser.

Analytical or Performance Cookies

These allow us to recognize and count the number of visitors to Our Platforms and understand how such users navigate through Our Platforms (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located).

Functional Cookies

These improve the functional performance of Our Platforms and make them easier for you to use. For example, cookies are used to remember that you have previously visited a portion of Our Platforms and asked to remain logged into it (e.g., this saves your username). These cookies qualify as persistent cookies because they remain on your device for use during your next visit to the Site. You can delete these cookies as detailed below.

Marketing Cookies

These record your visit to Our Platforms, the pages you have visited, and the links you have followed to recognize you as a previous visitor, and to track your activity on Our Platforms and other websites you visit. These cookies qualify as persistent cookies because they remain on your device. You can opt out of these cookies through our cookie banner. If you opt-out, you will need to apply these opt-out settings in each browser and device from which you wish to opt out.

Third-Party Cookies

We also use certain third parties to provide features or functionality through the Service. For example, we use HubSpot to power some of the forms on Our Platforms that you may use to contact us, and we use YouTube to host certain videos available on Our Platforms. Additionally, in the United States we use Paycom and in Europe we use Workable to assist with recruiting and employment application services. You may learn more about HubSpot’s cookies at https://legal.hubspot.com/cookie-policy, YouTube’s cookies at https://policies.google.com/technologies/cookies, Paycom’s cookies at https://paycom.com/privacy/, and Workable’s cookies at https://www.workable.com/privacy.

Do-Not-Track Signals

At this time, Glass Lewis does not recognize automated browser signals regarding tracking mechanisms, which may include “do-not-track” instructions.

You may also prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access Our Platforms, however, you might not be able to access or use important functions or features of the Services, and you may, for example, be required to re-enter your log-in details.

  1. Children’s Privacy

The Service is not intended for users under the age of 13 and Glass Lewis does not knowingly collect personal information from individuals under the age of 13. If you are aware of, or suspect that, someone under the age of 13 is using the Services without permission, please notify us immediately by contacting us as detailed in the “How to Contact Us” section below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.

  1. Our Use of Personal Information

We collect and use your personal information for the following purposes, which may include access to and use of this information by our employees, contractors, and agents:

  • Providing the Services to you and providing services requested by, or reasonably anticipated within the context of our relationship with you;
  • In our research regarding the company for which you work or are otherwise affiliated, such as being a director or chair on such company’s board;
  • To engage with you, on behalf of the company for which you work or are otherwise affiliated, such as being a director or chair on such company’s board, either on our own behalf or on behalf of our clients for their active ownership, engagement, and other stewardship interests and responsibilities;
  • Managing our relationship with you;
  • Responding to your inquiries or requests, and requesting feedback;
  • Administering promotions, events, or surveys;
  • Providing promotional material or other marketing materials that we believe will be of interest to you;
  • Analyzing and evaluating your employment application for any open positions at Glass Lewis;
  • Analyzing use of Our Platforms;
  • Keeping track of your login username and password;
  • Personalizing the Our Platforms (e.g., displaying your name when you login to Our Site);
  • Detecting security incidents and protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible;
  • Complying with legal and regulatory requirements.
  1. Our Disclosure of Personal Information

We may share your personal information with the following categories of third parties:

  • Service providers, including hosting providers and IT outsourcing, payment processors, contact management software providers, customer relationship management providers, marketing providers, third-party providers of products and services made available as part of our Services, and human resources or other employment and recruiting service providers. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
  • Other users when you respond to a survey or questionnaire.
  • Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
  • With third parties in connection with a change to the control or financial status of Glass Lewis, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
  • Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.
  • The owners of Glass Lewis.
  1. Your Privacy Choices

If you no longer want to receive our newsletter, emails, or other marketing communications, you may unsubscribe at any time by following the unsubscribe options in the communication itself or by emailing us at the contact information below under How to Contact Us.

Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account or purchases placed through Our Platforms.

By logging into your account(s) on Our Platforms, you may view, update, and/or delete certain information associated with your account. You may also contact us at privacy@glasslewis.com. We may maintain information associated with your account after you cancel for our internal purposes.

  1. Security

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Services. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

You play an important role in keeping your information secure. You should not share your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at the contact information in the “How to Contact Us” section below.

  1. Additional Disclosures for Residents of California

For residents of California, this section describes how we collect, use, disclose, and “sell” (as defined under California law) the personal information of California residents, and the rights you may have under California law. These disclosures are intended to supplement this Privacy Statement with information required by California law.

To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section Information We Collect above.

We collect this personal information, as further described in the Our Use of Personal Information section above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.

We may share personal information with the third parties listed above in the section Our Disclosure of Personal Information. Below, we have provided more detail regarding the two ways we share your personal information: (a) “sales” of information (as defined under California law) and (b) general disclosures of information for a business purpose.

Sales of Personal Information

Under California law to “sell” and the “sale” of personal information broadly includes any disclosure of information in return for something of value, and this value does not need to be monetary as in a traditional sale.

Glass Lewis does not share personal information in exchange for monetary payment or otherwise currently engage in sales of personal information. Accordingly, we do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.

Disclosure of Information for a Business Purpose

To manage our business and provide services to you, we sometimes share personal information with third parties. These third parties cannot further collect, sell, or use the personal information we share with them except as necessary to perform our purposes, as instructed by us.

In the past 12 months, we may have disclosed the following categories of personal information to the following categories of third parties for our operational business purposes:

  • Identifiers – Service Providers
  • Financial and Transactional Information – Service Providers
  • Inferences – Service Providers
  • Device Information – Service Providers
  • Internet Activity – Service Providers

Your Rights

Under California law, you have a right to notice, upon collection, of the categories of personal information collected and the purposes for which the information will be used. You have the right to access a copy of the categories and specific pieces of personal information about you that we collect, use, disclose, and/or sell, and the right to ask us to delete or anonymize your personal information, subject to some exceptions. You also have the right to opt-out of the sale of your personal information, though at this time we do not engage in any sales of personal information. Finally, you have the right to be free from discrimination for exercising your rights.

If you wish to exercise the right to access or delete your information or have any questions or concerns regarding the processing of your personal information, please contact privacy@glasslewis.com with the subject line “California Privacy” so that we can get your email to the right team. We will respond to your request consistent with applicable law.

Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. If we possess appropriate information about you (e.g., name, email, address), we will attempt to verify your identity using that information. If it is not reasonably possible to identify you, we may not be able to respond to your request.

To use an authorized agent to make a request on your behalf, we may need the authorized agent to provide proof that you gave the authorized agent signed permission to submit the request on your behalf. We may also require you to verify your identity directly with us.

  1. Additional Disclosures for Residents of the European Union (EU) and the United Kingdom (UK)

This section provides additional information for residents of the EU and UK.

Data Transfers

As a US-based company, many of our operations are conducted in the United States and in order to provide the Services, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area, and where applicable, we implement the standard contractual clauses approved by the European Commission.

Retention of Your Personal Information

We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise required or permitted by law.

Legal Basis for Processing Your Personal Information

Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out in the Our Use of Personal Information section above, including: (i) as may be necessary to perform a contract with you; (ii) as necessary to comply with a legal obligation; (iii) consent (where consent has been provided as appropriate under applicable law); and (iv) as necessary for our legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Service).

Automated Decision-Making

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.

Your Rights

As available and except as limited under applicable law, individuals in the EU and UK have the rights described below:

  • You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
  • You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
  • You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such information to comply with a legal obligation or to establish, exercise, or defend a legal claim.
  • You have the right to request that we restrict our processing of your personal information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
  • You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
  • Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise, or defend a legal claim.
  • Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information based on your consent before the point in time when you withdraw your consent or processing of your information based on other legal bases.
  • Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at privacy@glasslewis.com with the subject line “EU Privacy” so that we can get your email to the right team. We will respond to you request consistent with applicable law.

If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.

  1. Links to Other Websites

For your convenience, we may link to third-party sites and services, or otherwise display third-party content through Our Platforms to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit personal information, and we encourage you to review their policies before engaging with these third-party sites.

  1. Effective Date and Changes to This Privacy Statement

This Privacy Statement is effective as of the date at the top of this policy. Glass Lewis has the discretion to update this Privacy Statement at any time. When we do, we will revise the effective date at the top of this page. We encourage users to frequently check this page for any changes and to stay informed about how we are helping to protect the personal information we collect, especially before you provide information, and particularly personal information, directly to us through the Service. In the event of a material change to this Privacy Statement, we will communicate this to you through a message on Our Platforms and/or via email informing you of the change.

  1. How to Contact Us

If you have any questions about this Privacy Statement or our Services, please contact us at privacy@glasslewis.com.