Privacy policy

Privacy Policy effective January 12, 2023.

Introduction

This Privacy Policy describes how FirstQuadrant Inc. (“FirstQuadrant”, “we”, “us”, or “our”) collects, uses, and shares your personal information when you use our services, website, or applications (collectively, the “Service”).

Information we collect

We collect several types of information from and about users of our Service, including:

• Personal identifiers (such as name, email address, phone number)
• Professional information (such as company name, job title)
• Usage data (such as how you interact with our Service)
• Device information (such as IP address, browser type, operating system)

How we use your information

We use the information we collect to:

• Provide, maintain, and improve our Service
• Process transactions and send related information
• Respond to your comments, questions, and requests
• Send you technical notices, updates, and administrative messages
• Communicate with you about products, services, offers, and events
• Monitor and analyze trends, usage, and activities in connection with our Service
• Detect, prevent, and address technical issues

Data sharing

We may share your personal information with:

• Service providers who perform services on our behalf
• Professional advisors, such as lawyers, auditors, and insurers
• Business partners with whom we jointly offer products or services
• Third parties in connection with a business transaction such as a merger or acquisition

Data protection

We have taken steps to protect any personal information we process. However, please keep in mind that the internet is not completely secure. Although we are committed to protecting your personal information, it is your responsibility to ensure that you only access our services in a secure environment.

Rights

European Economic Area

If you live in the European Economic Area, you have certain rights under data protection laws. This includes the right to ask for access to your personal information, to request that it be changed or deleted, to limit how it is used, and to get a copy of it. You can also object to how your personal information is processed. To make such a request, please use the contact details provided. If we have your consent to process your personal information, you can withdraw your consent at any time. If you think your personal information is being used illegally, you have the right to complain to your local data protection authority. You can find their contact details at ec.europa.eu.

California Civil Code Section 1798.83

If you are a resident of California, you have the right to request information from us once a year free of charge. This information includes what kind of personal information we shared with third parties for marketing purposes, and the names and addresses of those third parties. If you would like to make this request, please contact us using the information provided.

If you are under 18 years old, reside in California, and have a registered account with us, you have the right to request that we remove any data you posted publicly on our Services. To do this, please contact us with your email address associated with your account and a statement that you live in California. We will not display the data publicly, but it may not be completely or thoroughly deleted from our systems.

CCPA Privacy Rights (California residents)

Under the California Consumer Privacy Act (CCPA), California residents have specific rights regarding their personal information:

• Right to know about personal information collected, disclosed, or sold
• Right to request deletion of personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising CCPA rights

To exercise these rights, please contact us using the information provided below.

Minors

We do not ask for or market to children under 18. If you are 18 or the parent/guardian of a minor, you can allow them to use the services. If we find out that we have collected data from someone under 18, we will delete the information and deactivate their account. If you are aware of any children under 18 using our services, please contact us.

Data breaches

If someone gets unauthorized access to, collects, uses, discloses, or disposes of your personal information, it is called a privacy breach. We will let you know if we think you may be at risk of harm. This could be serious financial harm or harm to your physical or mental health. If we find out about a security breach that could let someone access, use, or see your personal information, we will investigate and inform you at the earliest possible date.

Cookies and tracking technologies

We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

Do Not Track headers

Many web browsers, mobile devices, and mobile applications have a feature called Do-Not-Track (“DNT”). If you activate this feature, it sends a signal that you do not want your online browsing activities monitored and collected. No technology has been finalized yet that recognizes and follows DNT signals. Because of this, we do not currently respond to DNT signals. If a standard for online tracking is created in the future, we will let you know in an updated version of this privacy policy.

International data transfers

Your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data to the United States and process it there.

Partners

We work with a number of partners to provide the Service. These partners may have access to your personal information, and you accept their privacy policies by using FirstQuadrant. Please contact us if you would like to know more about our partners and the data we share with them.

Data retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

Updates

We may update this privacy policy from time to time. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

Questions

If you have questions or comments about this policy, you may contact FirstQuadrant Inc.’s Data Protection Officer (DPO):

• Address: 1209 N. Orange Street, Wilmington, DE 19801, United States
• Phone: +1 (440) 73 PABIO
• Email: [e-mail]