This Privacy Policy sets forth the privacy practices of Engine No. 1 (“Engine No. 1.,” “we,” “our,” or “us”) with respect to our collection, use, sharing, and disclosure of Personal Information, including, but not limited to, Personal Information collected through this website (the “Site”), how it is used, and the circumstances under which it may be shared and disclosed. This Privacy Policy constitutes a legally binding agreement between you and Engine No. 1 that conditions your use of the Site, where and as permitted by applicable law.

If you are a California resident, please review our California Privacy Note.

1. Personal Information We Collect

When you visit the Site and during our ordinary business activities, Engine No.1 may collect or ask you to provide certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs. The Personal Information we may collect from you may include personally identifiable information including names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such ascertain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under applicable law, that may be contained in the relevant materials, documents, or obtained through background searches.

2. Sources of Personal Information

We may collect Personal Information from:

• Your communications with us;
• Your transactions with us;
• Services providers; and
• Affiliates.

3. How we Use Personal Information

We use Personal Information for the following business purposes:

• To provide our products and services and serve your investment needs;
• To provide customer service and process your requests and inquires;
• To offer new products and services;
• To process subscriptions;
• To open an advisory account or securities brokerage account;
• To process transactions for client accounts;
• For account maintenance;
• To confirm your identity;
• To communicate with you;
• To protect the security and integrity of the Site;
• To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
• To comply with and enforce applicable legal requirements.

4. How we Share Personal Information

Your privacy is important to us. Engine No. 1 does not disclose any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted by law. We do not sell any Personal Information.

Every client has the right to direct Engine No. 1 not to disclose the Personal Information about that client to a nonaffiliated third party. If a client would like to exercise its right to opt out of this Privacy Policy, each client must provide a written statement exercising that right. This right to opt out may be exercised at any time and will remain in effect until written notice revoking said right is received by Engine No. 1 from the client. However, in the event Engine No. 1 encounters circumstances where it is compelled by law to disclose a client’s Personal Information, Engine No. 1 must provide, to non-affiliated third parties, a client’s Personal Information even if the client has exercised its right to opt out.

5. How we Protect Personal Information

Engine No. 1 seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees requiring that Personal Information to provide our products or services.

6. Notice for Residents of the European Economic Area and United Kingdom

Engine No. 1 does not currently offer its products or services to natural persons resident in the European Union or the United Kingdom (“EEA/UK”) and, accordingly, is not required to comply with the EU General Data Protection Regulation (“GDPR”). Any personal data provided to us by you will be processed in the United States or other jurisdictions outside the EEA/UK which may not afford the same protections of personal data as under the GDPR.

7. Contact Us

If you have any questions or comments about this Privacy Policy, please feel free to contact Engine No. 1 at [email protected].

8. Privacy Notice For California Consumers

Last updated: January 9, 2023

This notice contains disclosures required by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”). Consumers with disabilities may access this notice by emailing [email protected].

Information We Collect.

In the past 12 months, we have collected and shared for a business purpose the following categories of sensitive personal information or other personal information (“Personal Information”):

Personal Information does not include information that is publicly available, de-identified/ aggregated, or subject to HIPAA or GLBA.

We collect Personal Information from the following categories of sources: 

• Your communications with us; 
• By observing your actions on our website or [app];
• Service providers, including, but not limited to:  administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, employment agencies, credit bureaus;
• Affiliates not under the Engine No. 1 brand;
• Nonprofit organizations; and
• Government entities.

We do not knowingly collect, solicit or sell Personal Information from anyone under the age of 16.

Purpose for Collection and Use of Personal Information.  We may collect or use Personal Information for one or more of the following purposes:

• Providing you with information about our products and services;
• Providing you with performance and other updates;
• One or more of the following business purposes:
  • Performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics;
  • [Auditing related to our interactions with you];
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Internal research for technological improvement;
  • Internal operations;
  • Activities to maintain and improve our services; and
  • Short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you. 

Sharing Personal Information.  We may disclose Personal Information to:

• Service providers, including but not limited to: [administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, employment agencies, credit bureaus];
• Affiliates;
• Business partners;
• Legal or government regulatory authorities as required by applicable law;
• In connection with a potential business transfer;  and
• Third parties to whom you or your agents authorize us to disclose such information in connection with services we provide to you.

In the past 12 months, we have not sold Personal Information to third parties.

Length of Time.

We will keep your sensitive personal information or any other Personal Information for as long as necessary to comply with our regulatory obligations.

Rights of California Consumers.  The CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:

• The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
• For certain categories of Personal Information, the right to request a list of what we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.
• The right to request that we delete your Personal Information, subject to certain exceptions.
• The right to opt out of our sale(s) (if any) of your Personal Information.
• The right to request we correct any inaccurate Personal Information maintained about you.
• The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
• The right not to receive discriminatory treatment for exercising your CPRA rights.

You may submit requests relating to your exercise of CPRA rights to us via:

            Via phone: (855) 322-4512 

            or

            email [email protected]

            or 

            through your Engine No. 1 contact

You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (2) sufficient detail that allows us to properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Questions

If you have questions regarding this Notice, please contact us at [email protected].