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Privacy Policy

Last updated December 7th, 2020

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.

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 website@engine1.com.