July 23, 2020
NetRoadshow, Inc. and its group of affiliated companies, Financial Software and Services, Inc., Secure Share Network, LLC, and Apparity, LLC (collectively, "NetRoadshow") value the trust and confidence of their customers, employees, and business partners and respect individual privacy. NetRoadshow strives to uphold the highest ethical standards in all of its business practices, and collects, uses, and discloses personal information in a manner consistent with the laws of the countries in which it does business. Capitalized terms not defined elsewhere in this Policy are defined in Section 10.This Privacy Policy (this "Policy") applies to the processing of (a) personally identifiable information ("Personal Data") that NetRoadshow collects through our websites www.netroadshow.com; www.structuredfn.com; www.researchfn.com; www.om.netroadshow.com; www.retailroadshow.com; www.netroadshow.com/meetmenow; and www.apparity.com (each a "NRS Website") from registered users of the Services offered by NetRoadshow ("Registered Users") and (b) Personal Data transferred to NetRoadshow by its customers for specialized data processing services.
1. BACKGROUND
NetRoadshow provides global business to business services to investment banks, issuers of debt and equity securities, and corporations (collectively, the "Services"). NetRoadshow is committed to supporting its customers’ compliance with all applicable EU data protection requirements, including those set out in the General Data Protection Regulation ("GDPR"). Among other requirements, GDPR requires NetRoadshow to use third-party data processors who guarantee their ability to implement the technical and organizational requirements of the GDPR. We are also prepared to provide our customers with contractual commitments regarding our commitment to implement additional contractual provisions required by the GDPR. https://www.netroadshow.com/nrs/home/en-us/dpa.pdf: These provisions include our commitment to (i) respond to requests from data subjects to correct, amend or delete personal data; and (ii) be made aware of and report personal data breaches to relevant supervisory authorities and data subjects in accordance with GDPR timeframes.
2. PROCESSING OF PERSONAL DATA
The Services may include the transfer to NetRoadshow of Personal Data. NetRoadshow uses the Personal Data solely to provide Services to its customers. When NetRoadshow receives Personal Data, NetRoadshow is acting as the "processor" and its customer or business partner is the "controller" of such data. NetRoadshow's customers or business partners retain responsibility for obtaining the appropriate consents or other lawful basis for processing such Personal Data under applicable EU law. With respect to data generated as part of the use of NetRoadshow Services, including user name and password, NetRoadshow acts as a "controller". When NetRoadshow hosts a conference call through MeetMeNow, it acts as a "controller" with respect to call data retained. See Section 5 for additional information.
3. RIGHTS OF DATA SUBJECTS
Any visitor to an NRS Website may request access to, and the opportunity to update, correct, transfer, or delete, his or her Personal Data by contacting our Chief Privacy Officer (chiefprivacyofficer@netroadshow.com) for assistance. If you are a resident of the EEA about whom NetRoadshow holds Personal Data on behalf of one of our customers or business partners, you may request access to, and the opportunity to update, correct, or delete, such Personal Data from our customer. If we do not have authority to permit you to access, update, correct, or delete, your Personal Data, we will assist you in contacting our customer who can handle your request.
4. RESPONSIBILITIES AND MANAGEMENT
NetRoadshow has a Director of Privacy who is responsible for overseeing our information security program, including our compliance with GDPR. The Director of Privacy reviews and approve any material changes to this program as necessary. You may direct questions, concerns, or comments regarding this Policy to chiefprivacyofficer@netroadshow.com.NetRoadshow will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects while providing Services to its customers.All of our employees and consultants are required to maintain the confidentiality of Personal Data. Any employee or consultant that NetRoadshow determines is in violation of these policies will be subject to discipline, up to and including termination of employment and/or criminal prosecution.
5. INFORMATION WE COLLECT
User Information
Registered Users are individuals that represent businesses with whom NetRoadshow or NetRoadshow's customers and business partners have a business relationship. NetRoadshow collects identifying information from Registered Users including names, addresses, work phone numbers, work email addresses, IP address, browser type, etc. This information is used for providing the Services, validation of identity, managing transactions, reporting, diagnosing technical problems, other operations related to providing the Services to NetRoadshow's customers and business partners. NetRoadshow only uses the Personal Data of Registered Users for purposes of providing the Services, responding to support questions, providing activity monitoring to customers, and other matters related to the Services. NetRoadshow does not use Personal Data of Registered Users for marketing or promotional purposes.The legal basis on which we process Registered User data is our legitimate interest to deliver and manage our services, validate user identity, and manage transactions. This data is retained indefinitely and is only deleted upon user or customer request.
Documents and related information
In connection with certain Services (e.g., Document Delivery Services and Data Room Services), Registered Users have the ability to add comments and annotations to documents which are stored and processed by NetRoadshow, and up load files and due diligence information which could include Personal Data. NetRoadshow has no control over the Personal Data which NetRoadshow customers and business partners upload into the Services.
Analytics data
NetRoadshow may also track and analyze non-identifying and aggregate usage and volume statistical information from Registered Users, and we may provide such information to third parties that assist us for these purposes. NetRoadshow may collect analytics data, or use third-party analytics tools and services, to measure traffic and usage of the Services. These tools collect information sent by the browser or mobile device or a Registered User, including the pages visited and other information that assists NetRoadshow in administering and improving the Services. Specifically, NetRoadshow has implemented Google Analytics to improve the quality of the user experience and administer and improve the Services. As implemented at NetRoadshow, the Google Analytics cookie collects technology data including browser, operating system, screen resolution, screen colors, flash version, and java support; session data, such as the number of new users and returning users, frequency data, and recency data, and engagement; and geographic data, including language and location. You may obtain more information about data collected by Google Analytics here. You can opt-out of Google Analytics by installing a plug-in to for browser available from Google here. Similarly to Google Analytics, NetRoadshow has implemented FullStory to Provide assistance in navigation, provide assistance during the visit, analyze your use of our services in order to improve the quality of the user experience and help diagnose user issues. As implemented at NetRoadshow, and in addition to the data collected by Google Analytics noted above, the FullStory cookie also collects information on your use of the Services, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol ("IP") address. You may obtain more information about data collected by FullStory here.If you wish to prevent all websites using the FullStory Services to be able to record activity, you can opt-out of the FullStory Services. Opting out will create a cookie that tells FullStory to turn off recording on any site which uses the FullStory Services. The cookie is available here.The legal basis on which we process this data is our legitimate interest to provide better customer service, address bugs, and enhance the user experience for our products. When legitimate interests serve as the basis for data processing, you have the right to object at any time.Analytics data in aggregated form is kept indefinitely. Data in an identifiable form is kept for six months.
Video Conferencing
When you join a call via MeetMeNow, your name is collected for the duration of the call for the purpose of providing this information to other users on the call to enhance the call experience. Your name may be stored after the call to allow for troubleshooting and enhancement of the MeetMeNow product.This information is processed based on our legitimate interest in providing an optimal product experience.
6. HOW WE PROTECT YOUR INFORMATION
NetRoadshow uses commercially reasonable and appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of Personal Data of Registered Users and Personal Data. All Personal Data is stored and processed in encrypted computer databases and servers. NetRoadshow uses Secure Socket Layer (SSL) technology to protect Personal Data using both server authentication and data encryption during transmission.While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur, and we cannot warrant the security of any information that you provide to us. You are responsible for securing and maintaining the privacy of any password(s) and account registration information used with NetRoadshow.
7. DISCLOSURE OF PERSONAL INFORMATION
Except as otherwise stated in this Policy, NetRoadshow does not disclose or share Personal Data with third parties. NetRoadshow does not sell, rent, or otherwise provide Personal Data to any third parties for marketing or promotional purposes.Disclosure of user information and activity may be made to NetRoadshow customers for purposes of providing audit logs with respect to the customer’s data hosted by NetRoadshow. NetRoadshow retains the right to disclose Personal Data as required by law, such as to comply with a subpoena or similar legal process to the extent provided in the agreements with NetRoadshow and its customers or to respond to a government request. NetRoadshow may also may be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
8. THIRD PARTY PROCESSORSNetRoadshow may share information, including Personal Data, with its third-party service providers used to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process Personal Data for the purpose of providing these services for us; however, we do not permit our third-party service providers to use any Personal Data that we share with them for their marketing or promotional purposes or for any other purpose than as necessary to provide services to us.
9. POLICY UPDATESThis Policy may be updated from time to time. Following each update, the date of the last revision will be reflected at the end of the page. This page may be bookmarked to facilitate periodic review of this Policy and to note recent updates. Neither this Policy nor any update to it will affect or modify any contract between NetRoadshow and its customers.10. DEFINITIONS"Data Room Services" means a secure on-line repository for offering and due-diligence materials for debt offerings, equity offerings, and private transactions made by or for the account of a NetRoadshow customer."Document Delivery Services" means the electronic delivery of securities transaction related materials, such as preliminary, amended, and final, offering memoranda and prospectuses to Registered Users.
We collect information from you when you submit an application or submit an order.
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
• To personalise your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To quickly process your transactions.
• To send periodic emails regarding your order or other products and services.
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Yes, we store 'cookies' for Google Analytics.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, Some of the features that make your site experience more efficient may not function properly. It won't affect the user's experience that make your site experience more efficient and may not function properly.
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
• Users can visit our site anonymously.
• Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.
• Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.
You will be notified of any Privacy Policy changes:
• On our Privacy Policy Page or via email
You can change your personal information:
• By submitting a request or logging into your billing area.
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
• Within 2 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions
• Process orders and to send information and updates pertaining to orders.
• Send you additional information related to your product and/or service
To be in accordance with CANSPAM, we agree to the following:
• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at email@email.com and we will promptly remove you from ALL correspondence.
