Last updated July 25, 2022
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
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.
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
8. Privacy Notice For California Consumers
Last updated: July 25, 2022
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:
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;
- 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;
- 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
email [email protected]
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.