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GEODE CAPITAL MANAGEMENT

CALIFORNIA PRIVACY POLICY/NOTICE AT COLLECTION

This Privacy Policy/Notice at Collection (“Policy”) applies only to clients and other users who reside in the State of California (“consumers” or “you”), including all California users of our Website, www.geodecapital.com (“Site”). This Policy is intended supplement the existing Privacy Policy, which is incorporated herewith in its entirety, and to disclose how Geode Capital Management, LLC (together with its affiliates, "Geode” herein) collects, uses and discloses personal information about users of our Site, as well as to explain the choices and right individuals have regarding their personal information.

By using our Website, including any of our service providers’ services, you agree to the collection, use, and disclosure of your information as set forth in this Policy. We may modify this Policy from time to time. Your continued use of our Website constitutes your agreement to any updated Policy on a prospective basis.

I. THE INFORMATION WE COLLECT

We collect information directly from individuals online, as well as automatically through the use of our Site.

Information Collected Directly

We may collect personal information about you directly from you. For example, personal information may be collected when you contact us through the Site or via email or otherwise provide us information through the Site. Generally, the information we collect may include your:

  • Personal master data (e.g. first name, title, address)
  • Communications data (e.g. telephone, mobile phone, email, fax)
  • Contract master data (contractual relationship, interest in Geode’s services and contractual fulfilment)
  • Customer history (e.g. assets)
  • Contract billing data
  • Other information related to your use of our Site and services

Information Collected Automatically

Website tracking enables us to analyze Site uses and to continuously optimize the website for visitors based thereon. Statistical tools may be used for this purpose, such as to record how often a page has been opened.

We collect personal information about you automatically through, for example, the following platforms:

1. Google Analytics and Visitor Analytics

This uses your HTTP requests, browser/system information, and first party cookies. It collects:

  • Number of users and sessions
  • Session duration
  • Operating systems
  • Device models
  • Geography
  • First launches
  • App opens
  • App updates
  • Demographics: gender & age

2. Cookie Information

Our Site distinguishes between cookies that are strictly necessary for the technical functions (functional cookies) and cookies that are not strictly necessary for the technical functions (optional cookies). It is generally possible to use the Site without activating optional cookies. These are the types of cookies that we use:

Necessary or Essential Cookies

  • These cookies help make the Site usable by enabling basic functions like remembering your preferences as to whether you wish to allow us to store cookies and remembering other selections you have entered when you navigate the Site. The Site cannot function properly without these cookies.

Preference Cookies

  • These cookies enable the Site to remember information that changes the way the Site behaves or looks, like your preferred language or the region that you are in. 

Statistic or Analytics Cookies

  • These cookies help us understand how visitors interact with the Site by collecting and reporting information anonymously. We use these cookies to collect and store information about website visitor behavior (e.g., store information about what pages are visited, how long visitors are on the Site, what users click on), and to monitor and provide statistics on how the Site is used (e.g., recognize and count the number of visitors; see how visitors move around the Site)

Marketing and Social Sharing Cookies

  • These cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers

Unclassified Cookies

  • Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

3. Cookie Opt-Out

You can prevent cookies from being saved by changing the preferences of your browser software accordingly. However, we would like to point out that in this case you may not be able to use all functions of this Site to their full extent. Furthermore, you can prevent the data generated by the cookie and related to your use of the Site (including your IP address) from being transmitted to Google and then processed by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=us.

4. Managing cookies and website tracking

You can manage cookie and tracking settings in your browser. If you want to disable all cookies, you must go to your browser settings and disable cookies. You should note that this may affect the functionality of the website.

Please note: The settings you make only relate to the browser that was used.

II. OUR USE OF PERSONAL INFORMATION

It is the business objective of Geode to provide you with access to our services

Geode is entitled to undertake all commercial operations, and undertake all measures that relate to its business objective, or which appear directly or indirectly conducive to it, as well as occasional advertising measures. This includes the improvement of our products and articles and the improvement of customer satisfaction.

This business objective may require that Geode collect, process and use personal data in close cooperation with development, production, sales and service partners.

Every instance of collecting, processing and using personal data takes place on the basis of legal provisions exclusively for the fulfilment of the business objective defined above.

More particularly, we use the information (including personal information, if any) that we collect online as follows:

  • Providing support and services: To provide and operate our Site and company, communicate with you about your use of the Site and company’s services, and to provide troubleshooting and technical support, respond to your inquiries, communicate with you, and for similar service and support purposes.
  • Responding to your requests: To respond to your inquiries and consider your request or application.
  • Newsletters, mailing lists and direct marketing: For direct marketing purposes, including to send you newsletters, client alerts and information we think may interest you..
  • Analytics and improvement: To better understand how users access and use the Site, and our services, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop services and features.
  • Protect our legal rights and prevent misuse: To protect the Site and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this Policy.
  • Comply with legal obligations: To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements.
  • General business operations: Where necessary, for the administration of our general business, payment, accounting, recordkeeping and legal functions.
  • Anonymous and de-identified information: We may create and use anonymous and de-identified information to assess, improve and develop our business, products and services, and for similar research and analytics purposes.

III. DISCLOSURE OF PERSONAL INFORMATION

We will not rent or sell your personal information, nor will we share it with third parties for their marketing purposes. If this policy changes in the future, we will notify you and allow you the opportunity to opt-in.

We may share personal information with the following categories of third parties:

  • Third party service providers that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services.
  • Our affiliates.
  • Our professional advisers, such as lawyers and accountants.

In addition, we may disclose personal information to other third parties under the following circumstances:

  • Business transfers: As part of any merger, sale and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.
  • Legally required: If we are required to do so by law (e.g., to law enforcement, courts or others, including, but not limited to, in response to a subpoena or court order).
  • Protect our rights: Where we believe it necessary to respond to claims asserted against us, comply with legal processes (e.g., subpoenas or warrants), enforce or administer our agreements and terms, or for fraud prevention, risk assessment, investigation, and to protect the rights, property or safety of Geode’s clients and customers, or others.

We may also share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

IV. OTHER COOKIES AND SIMILAR DEVICES

The categories of the cookies and tracking devices we use are described above. Some of our service providers may use cookies, pixels, log files and other mechanisms to gather information about your use of our Site. You would need to view their privacy policies to determine the precise tracking devices they use.

V. DIRECT MARKETING

We may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time by following any opt-out instructions provided or emailing us at infoprotection@geodecapital.com. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

VI. WEBSITE CONTENT ACCESSIBILITY

We are currently working to adhere to the Web Content Accessibility Guidelines for the visually impaired (such as screen readers, speech-recognition software, etc., including website text having the capability to convert to sound for the visually impaired who use assistive technology and any videos having the capability to add captions for the hearing impaired).

VII. ACCESS, DELETION, OPT OUT, NON-DISCRIMINATION & EXCEPTIONS

If you would like to review the personal information we have collected about you via the Site, or request that we update, delete, or not sell it, please contact us at (800) 777-6757, or through email at infoprotection@geodecapital.com.

Right to Know and Access. You have the right to know and access the following personal information, obtained or handled by us in the 12 months prior to your request:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose for collecting your personal information;
  • The categories of third parties with whom we have shared your personal information;
  • The specific pieces of personal information we have collected about you, if you so request; and
  • Whether we sell your personal information to third parties for their own direct marketing purposes.

Your rights to know and access are free and may be requested up to twice a year.

Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

  • Complete your transaction, provide you a good or service or perform a contract between us and you;
  • Protect your security and prosecute those responsible for breaching it;
  • Fix our system in the case of a bug;
  • Protect the free speech rights of you or other users;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

If we are unable to delete the information you have requested to be deleted, we will provide you with the basis of our denial of your request.

If we delete information you have requested be deleted, we may keep a record of your request for up to two years.

Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information to any outside party. We currently do not sell your information to any outside party and will notify you through our Policy if this policy changes.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment for your exercise of any of the privacy rights conferred by the California Consumer Privacy Act (CCPA).

Exercising Your Foregoing Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:

  • Telephone: You may call us at (800) 777-6757
  • Website: You may authenticate and exercise rights via our website, www.geodecapital.com.
  • Email: You may write to us to exercise rights at infoprotection@geodecapital.com. Please include the information requested so that we can process your request in an efficient manner.

The Steps We Take to Verify Your Request. We will take reasonable steps to verify your request. These steps include verifying your identity. In order for us to do so, you must provide a verifiable consumer request. The request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. If we cannot reasonably verify your request, we will be unable to provide the information you have requested.

Authorized Agent. If you have caused an authorized agent to make your request, please provide the following information: first and last name of the agent, physical address of the agent, email address of the agent, and a statement granting the agent the authority, along with why you are writing.

Response Timing and Format. We aim to confirm our receipt of your request for access or deletion within 10 business days. If you have requested access or deletion, we will provide you with requested information, to the extent specified above, or delete what you have requested to be deleted, to the extent specified above, within 45 days of receiving your request. If we require more time, we will inform you of the reason and extension period in writing.

Not Covered by This Policy

This Policy does not address or apply to:

  • Personal information that is exempt under Section 1798.145 of the CCPA,
  • Personal information we collect about employees, contractors, job applicants, officers, directors or medical providers,
  • Individuals who are not permanent California residents, or
  • Personal information we collect about individuals acting in their capacity as representatives (“B2B contacts”) of our clients, prospective clients, vendors and other businesses that we conduct business with, to the extent we use their personal information only in the context of conducting our business relationship with the respective business.

VIII. THIRD PARTY LINKS AND WEBSITES

Our Site may contain links to other websites whose information practices may be different than ours. Visitors should consult the other website's privacy notices as we have no control over information that is submitted to or collected by, these third parties.

IX. OUR COMMITMENT TO SECURITY

We employ security measures to prevent unauthorized access to information that we collect online. However, we cannot guarantee the security of your personal information. Notwithstanding the foregoing, you are solely responsible for (a) maintaining the security of your account(s) and (b) all activity that occurs under your account(s).

X. HOW TO CONTACT US

If you have any questions or concerns about this Policy or its implementation, you may contact us at (800) 777-6757. If at any time you decide that we should no longer hold any of your personal information, or you wish to change the use to which any such information can be put, please let us know by emailing us at infoprotection@geodecapital.com.

XI. REVISIONS TO THIS POLICY

We reserve the right to revise this Policy or any part of it from time to time. Please review the Policy periodically for changes. If we make material changes, we will endeavor to provide notice ahead of such changes, such as through a notice on www.geodecapital.com.

XII. POLICY DATE

This Policy was last updated on November 11, 2021.