Updated and Effective: August 8, 2019
Issuer Direct Corporation (“Issuer Direct” "ID" or “we”) owns and operates various websites (the “Sites”).
Our Sites include, but are not limited to, the following:
l. Personal Information
A. Active Collection and Use:
In order to access the Sites, services and the information available on the Sites, you may be required to register with theSites and provide some personal information, such as your name, email address, telephone number and certain financial information, including but not limited to credit card information. If you provide us with personal information, we will retain and may use that information to contact or respond to you.
We also may retain or use your information for the period of time needed to pursue our legitimate business interests. This time period will not exceed 10years unless otherwise agreed by you in writing. Our legitimate business interests may include customizing the services we provide to you and to ensure compliance with Issuer Direct policies and applicable laws, ensuring you are satisfied with Issuer Direct's support and services, authentication confirmation for secure handling of Issuer Direct's clients' accounts, etc.We will retain such information even if you elect to delete your account with us but will only use it as described above.
We may share your personal information with our partners. For example, if you use our Investor Network website to research various companies, whether it be by downloading reports, streaming information, or participating in a blog, we may share the information we collect with the companies you are researching and those companies may have the right to use such information for their own purposes. Prior to using Investor Network, you will be required to complete a submission form that will allow you to specify how your information will be used and who will have rights to it.
We also collect potentially personally identifying information like “IP addresses” (as discussed in more detail below) for logged in users and for users leaving comments on WordPress.com blogs. Issuer Direct only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below so long as the user in not logged in, except that blog commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog where the comment was left.
Our services collect, store and process this personal information on servers in the United States of America.
We will collect your personal information to:
Provide you with a tailored experience to our Platforms.
Notify you about your account activity.
Process transactions and collect requests as directed by you.
Provide customer support and resolve disputes.
Verify your identity and account information.
Identify, prevent, and report potentially prohibited, fraudulent or illegal activities.
Provide transaction, risk mitigation and “KYC -Know Your Customer” reports to our Financial Institution Partner(s) and/or merchants.
Contact you at your telephone number by voice orSMS to validate the telephone number or your account.
Notify you about important changes to ID’sPlatform and/or ID’s terms and conditions.
Provide you with news, offers and information about ID’s offerings based on your communications preferences.
Any other purpose that we disclose to you in the course of providing ID’s Services to you.
Compare and create audiences based on interest of your personal data and or requests.
B. Aggregate Information and Passive Information Collection:
From time to time, we may collect general, non-personal, statistical information about the use of the Sites, such as how many visitors visit a specific page on the Sites, how long they stay on that page, and which hyperlinks, if any, they “click” on.
We collect this information through the use of technologies such as “cookies”and “IP addresses,” which are discussed in greater detail below. Our system may also automatically collect operational information about the technology you use, such as your browser, type of computer, operating systems, internet service providers and the domain name of the Sites from which you linked to ourSites.
We collect this information in order to determine which areas of the Sites are most popular and to enhance the Sites for visitors. We may use this information for security purposes, to detect and to block security breaches and to provide you with a safe online environment. We may also share this information with our partners.
C. IP Addresses:
An IP address is a number that's automatically assigned to your computer whenever you're surfing the web. Web servers, the computers that “serve up” web pages; automatically identify your computer by its IP address. Issuer Direct collects IP addresses for purposes of system administration, to report aggregate information to third parties and to track the use of the Sites. When visitors request pages from the Sites, our servers log the visitors' IP addresses. It is not our practice to link IP addresses to anything personally identifiable, which means that a visitor's session will be logged, but the visitor remains anonymous to us. However, we reserve the right to use IP addresses to identify a visitor when we feel it is necessary to enforce compliance with the Site's policies or to protect Issuer Direct, theSites, its visitors, or others.
D. Cookies, Beacons and Successor Technologies:
By showing how and when visitors use the Sites, cookies help us see which areas are popular and which are not. Information such as the total number of visitors and pages viewed is most easily tracked with cookies. We may use the information from cookies to make improvements and updates to the Sites and to tailor our services to our visitors' needs.
Pages of our Sites may contain electronic images known as web beacons-also referred to as single- pixel gifs-that permit Issuer Direct to count users who have visited those pages and for other related website statistics-(e.g.,recording the popularity of certain website content and verifying system and server integrity). Web beacons are not used to access your personal information on the Sites; they are solely used to compile aggregated statistics concerning the use of the Sites. Web beacons collect only a limited set of information including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides.
In addition to the foregoing, we use certain analytics platforms, which will track certain personal information of yours. Information collected about you is limited to age, gender and affinity categories. If you would like to opt out of the collection of such information you may do so on your account page. Further, most Web browsers provide technology plugins that prevent your data from being collected and used by analytics platforms.
E. User Data Supplementation:
We may receive information about you from other sources, including publicly available databases or social media sites, combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you (for the purpose of creating more tailored advertising and products), may include:Purchased marketing data about our customers from third parties Data and other information available publicly on social media sitesF. Do Not Track Signals:
At this time we do not have the ability to comply with any setting within your web browser that would send “do not track” signals or other similar technology that would provide consumers the ability to exercise choice regarding the collection of personally identifiable information.
ll. Disclosure of Personal Information
A. Personally Identifiable Information:
We may use information collected via these Sites to improve the content of our Sites, to customize the Sites to your preferences, to communicate information to you (if you have requested it), for our marketing and research purposes, to ensure you are no longer contacted inthe event you unsubscribe from marketing campaigns, to market future available services and software of relevant interest to you, and for any other purpose specified.
B. Legal Notice:
In certain situations, Issuer Direct may be required to disclose personal data in response to lawful requests by public authorities, including to comply with national security or law enforcement requirements.
We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request or subpoena.
If Issuer Direct is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.
We may buy other businesses or their assets or sell our business assets.Customer information is generally one of the business assets involved in such transactions. Thus, in the event that Issuer Direct or all of its assets are acquired, or in cases of liquidation, dissolution, reorganization or other transfer of the business, customer information, including any visitor information collected through the Sites, may be one of the transferred assets.
Finally, Issuer Direct reserves the right to disclose visitor information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who maybe causing injury to or interference with (either intentionally or unintentionally) Issuer Direct rights or property, other visitors, or anyone else that could be harmed by such activities. Issuer Direct also reserves the right to disclose visitor information when we believe in good faith that the law requires it. However, we will have no liability for disclosure of information obtained due to errors in transmission or the unauthorized intervention of third parties.
C. Agreement Information:
We may group information into aggregate visitor data in order to describe the use of the Sites to our existing or potential business partners or other third parties, or in response to a government request. However, please be assured that this aggregate data will in no way personally identify you or any other visitors to the Sites.
III. Links to Other Sites
Protecting the security of your personal information is very important to us.
When you transmit personal information from your computer to our servers, your information is protected by both a “firewall” (a combination of computer hardware and software that helps keep unauthorized visitors from accessing information within our computer network) and industry standard SSL (secure socket layer) encryption. Once we receive your transmission, we will take reasonable precautions to ensure its security on our systems. While we utilize all of our security and data protection preventative measures, the internet is inherently insecure. As a result, while Issuer Direct strives to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personal information.
Users are required to sign-in to specific secured areas of the Sites and services using a user ID and password. These authenticate the user and are designed to safeguard against unauthorized access and use of a user's account.The user ID and password are used on a secure web page and encrypted when transmitted over the internet.
The safety and security of your information also depends on you.
If you have access to password-protected features, never share your password with anyone else, notify us promptly if you believe your password security has been breached, and remember to log off of this site before you leave your computer. Similarly, any personally identifiable information or personally sensitive data that you disclose through online forums and blogs hosted on theSites, may be collected and used by others. We recommend caution when giving out personal information to others in these public online forums.
If at any point you suspect or become aware of a security incident (i.e. your password is stolen or you receive suspicious communication from someone holding themselves out to be an Issuer Direct employee or from a fake website claiming to be affiliated with Issuer Direct), please forward the communication to us or report the incident by email to email@example.com as soon as possible.
We do not knowingly collect information from children under the age of 13 on the Sites. If you are under the age of 13, please do not provide any personal information to us. If we become aware that we have collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.
VI. Changes to These Terms
VII. Access and Review of Your Personal Information
Our services collect, store, and process personal information on servers in the United States of America.
When using our Sites and services, we make commercially reasonable efforts to provide you with access to your personal information and either correct this data if it is inaccurate or delete inaccurate data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
Issuer Direct provides you with information about whether we hold, or process on behalf of a third party, any of your personal information on your account page.
You may access, correct, or request deletion of your personal information by accessing your account page. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
We will respond to these requests within a reasonable timeframe.
Users must identify themselves and the information requested to be accessed, corrected or removed prior to processing such requests, and we may decline to process such requests that are deemed unreasonable or inappropriate. In any case, the information access and data corrections are performed free of charge, except if doing so would require a disproportionate effort. Due to the methods that we maintain certain services, once your information is corrected or deleted; residual copies may take a period of time before they are deleted from our active systems and may remain in our backup systems.
VIII. International Privacy Principles
A. EU-U.S. and Swiss-U.S. Privacy Shield Principles for EU & Swiss Data Transferred to the United States:
Issuer Direct is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Issuer Direct remains liable for all data transferred under the Privacy Shield Framework(s)unless we can prove we were not a party giving rise to the damages.
Pursuant to the Privacy Shield Frameworks, we acknowledge the right of EU and Swiss individuals to access their data. Such individuals may also correct, amend, or delete the personal information we hold about you if it is inaccurate or has been processed in violation of the Privacy ShieldPrinciples. Individuals wishing to exercise this right should refer to Section VII. Access and Review of Your Personal Information for more details regarding how they can gain such access.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org. In compliance with the Privacy Shield Principles, Issuer Direct commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Issuer Direct at :email@example.com
In compliance with the Privacy Shield Principles, Issuer Direct commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contactIssuer Direct at: firstname.lastname@example.org.
Issuer Direct has further committed to refer unresolved Privacy Shield complaints to BBB EU PrivacyShield, an alternative dispute resolution provider located in the United States.If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.bbb.org/EU-privacy-shield/file-a-complaint/
for more information or to file a complaint. The services BBB EU Privacy Shield are provided at no cost to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. SeePrivacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Issuer Direct is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.In certain situations, Issuer Direct may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
B. GDPR for EU Individuals
As of May 25th, 2018, Issuer Direct has been in compliance with Regulations (EU) 2016/679 of the European Parliament and of theCouncil of 27 April 2016 on the protection of natural persons with regard to the processing of on the free movement of such data, known as the GeneralData Protection Regulation (“GDPR”), and Issuer Direct’s processing and control of personal information if you are located within the EuropeanUnion will be in accordance with the standard set forth in the GDPR.
EU individuals with GDPR complaints are encouraged to contact us directly at email@example.com
. You also have the right to bring any grievance directly to the Data Protection Authorities (DPA’s) in your area. Please refer to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
to locate your specific DPA.
C. Email or Newsletter Preferences
You may also be provided an option to choose to subscribe to an email list. If you subscribe to our electronic mailing list and later decide to opt-out, simply follow the instructions that are included in each email.
. Such action could be email double opt in verification, SMS verification for two-factor authentication, and or a clickwrap or checkboxes to consent to the use.
. Issuer Direct values your trust and will take the appropriate measures to ensure that the Sites and services we provide to you are secure.