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Privacy Policy

Last updated June 16th, 2021

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 (“PersonalInformation”) in order to help us manage our relationship with you and serve yourinvestment needs. The Personal Information we may collect from you may includepersonally identifiable information including names, residential or businessaddresses, or other contact details, signature, nationality, tax identification orpassport number, date of birth, place of birth, photographs, copies of identificationdocuments, bank account details, information about assets or net worth, credithistory, information on investment activities, or other personal information, such ascertain special categories of personal data (including, where relevant, informationon political affiliations, ethnic origin, or criminal convictions), as specified underapplicable law, that may be contained in the relevant materials, documents, orobtained 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 PersonalInformation to nonaffiliated third parties, except to service or manage a client’saccount 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 PersonalInformation about that client to a nonaffiliated third party. If a client would like toexercise its right to opt out of this Privacy Policy, each client must provide awritten statement exercising that right. This right to opt out may be exercised atany time and will remain in effect until written notice revoking said right isreceived by Engine No. 1 from the client. However, in the event Engine No. 1encounters circumstances where it is compelled by law to disclose a client’sPersonal Information, Engine No. 1 must provide, to non-affiliated third parties, aclient’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 usecommercially reasonable efforts to ensure that Personal Information is kept secureand safe from any loss or unauthorized disclosure or use. We restrict access toour client’s Personal Information to employees requiring that Personal Informationto 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 personsresident 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 orother jurisdictions outside the EEA/UK which may not afford the same protections ofpersonal data as under the GDPR.

7. Contact Us

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

8. Privacy Notice For California Consumers

Last updated: June 16, 2021

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by emailing [email protected].

Information We Collect. In the past 12 months, we have collected the following categories of personal information about California consumers:

Category

Examples

A. Identifiers

A real name, alias, email address, Internet Protocol (IP) address, account name, or other similar personal identifiers.

B. Other personal information categories, as listed in the California Customer Records statute

A signature, telephone number.

C. Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

 

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

We collect personal information from the following categories of sources:

  • Your communications with us;
  • Service providers, including, but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, employment agencies, credit bureaus;
  • Affiliates not under the Engine No. 1 brand;
  • Nonprofit organizations; and
  • Government entities.

Use of Personal Information. We may use the personal information we collect for one or more of the following purposes:

  • Providing you with information about our products and services;
  • Providing performance and other updates;
  • One or more of the following business purposes:
    • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
    • Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance, etc.);
    • 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, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer.

Sharing Personal Information. We may disclose personal information in one or more of the categories identified above to:

    • Service providers, including but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, employment agencies, credit bureaus;
    • Affiliates;
    • Business partners;
    • Legal or government regulatory authorities as required by applicable law; and
    • In connection with a potential business transfer.

In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Rights of California Consumers. The CCPA 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, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information;
  • For certain categories of personal information, the right to request a list of what personal information (if any) 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 the personal information we have collected from you or maintain about you;
  • The right to opt out of our sale(s) (if any) of your personal information; and
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests relating to your exercise of rights under the CCPA to us:

Via phone: (855) 322-4512

or

email [email protected]

or

through your Engine No. 1 contact

We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum, a phone number or mailing address. If we are unable to verify your identity, we will need to deny your request.

You may designate an authorized agent to make a CCPA request on your behalf. In such case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf. In addition, we will ask you to either (1) verify your identity directly with us in the manner described above or (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.