This policy

1. This is Proxymity Limited’s (“Proxymity” or “we/us/our“) privacy policy that explains who we are, why and how we process your personal information, your rightsand how to contact us if you need to. For the purposes of this policy, “you” and “your” refers to individuals who:
   1. Use our website (https://proxymity.io/privacy-terms/);
   2. Use our platform, Investor Portal, Vote Impact, or any other products or services we offer (together with our website, the “Services”) (“End Users”);
   3. Represent our business customers, such as mutual funds or other intermediary entities (“Customer”);
   4. Represent any other companies with which we do business;
   5. Are seeking the opportunity to work for us.

2. Our contact detailsare set out at the end of this policy.

2.1   This policy sets out:

1. Collection and use of information
2. Cookies and other technologies
3. How we use your information
4. Our promotional updates and communications
5. Who we give your information to
6. Where do we store your information
7. How we protect your information
8. How long we keep your information
9. Individuals in the U.S.
10. Individuals in the UK and EEA
11. Our expenses
12. Changes to this policy
13. Contact us

2.2   Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

3. COLLECTION AND USE OF INFORMATION

The following is the personal data relating to you that we process:

3.1 Information you give us:

 

1. Your name.
2. Who you work for, and your job function or department.
3. Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).
4. Information about you that you give us by communicating with us by phone, by e-mail, via our Services, via social media or otherwise. It includes information you give us or that we obtain when you use our Services, supply us with goods or services, provide a bio to us, enquire about a product, place an order, enter a competition, promotion or survey, or contact us to report a problem, or do any of these things on behalf of the person that you work for.
5. Information relating to transactions with us involving you or the company you work for (for example, details of goods or services that we have supplied to, or obtained from, you, or the person you work for).
6. Profile information relating to you which you upload while signing up for or using, our Services, such as your date of birth, mailing address, username, mobile phone number.
7. Information about events to which you or your colleagues are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events (for example, your dietary requirements).

3.1.1  We collect this information when you give it to us by:

1. Filling in forms on our Services (or other forms that we ask you to complete);
2. Giving us a business card (or similar); or
3. As it relates to the content disclosed, corresponding with us by telephone, post, email or otherwise.

3.2 Information that we automatically collect from you when you use our Services include:

 

1. Technical information about you that we obtain when you use our Services or otherwise engage with us, which comprises of the Internet protocol (IP) address used to connect your computer to the Internet (through which we may obtain your approximate location), your login information, certain unique identifiers, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
2. Information about your use of our website, Investor Portal and/or Vote Impact, including the full Uniform Resource Locators (URL), clickstream to, through and from our Services (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our Customer service number or social media handle used to connect with our Customer service team.

3.2.1. We collect this information by:

1. Automatically collecting such usage information if you visit our Services (see, in addition, Cookies and other technologies, below).
2. Automatically collecting certain metadata regarding any exchange of emails, telephone conversations or other electronic communications with our employees and other staff members.

3.3 Information we collect from a third party

1. We may process your personal data that we have obtained from a third party. Personal data which is not collected directly from you may be collected if we have a business relationship with the organisation that you represent, your colleagues or other business contacts, if you direct such third parties to send us information (e.g., a summary of your account holding) or if you otherwise engage with us through a third party such as a social media platform. These third parties give us information about you comprising of your contact details or details of your role in the relationship.

4. COOKIES AND OTHER TECHNOLOGIES

Our use of cookies and other similar technologies to process personal data is explained in our cookie policy, which you should please read.

5. HOW WE USE YOUR INFORMATION

We will use the information to, as applicable:

5.1  Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you or the company you work for and us, including:

1. supplying goods and services to you, the company you work for or a Customer who is a service provider of the company you work for, or receiving them from the company you work for or a Customer who is a service provider of the company you work for, as the case may be;
2. administering your (or your company’s) account with us;
3. communicating about your account with us or as otherwise requested;
4. notifying you about changes to our Services.

5.2  Provide you with information about our Services we feel may interest you or the company you work for, if you have given your consent to receiving marketing material from us at the point we collected your information (where required), where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See ‘Our promotional updates and communications’.

5.3  Ensure, in our legitimate interests:

1. that content from our Services is presented in the most effective manner for you and for your computer;
2. that we protect our business from fraud, money-laundering, breach of confidence, cyber attack, theft of proprietary materials and other financial or business crimes;
3. that we comply with our legal and regulatory obligations and bring and defend legal claims;
4. that we provide you or the company you work for with the information, products and services you request from us.
5. to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
6. to keep our Services safe and secure.
7. where applicable, for measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
8. to allow you to participate in interactive features of our Services, when you choose to do so.

Information we receive from other sources

5.4  We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

6. OUR PROMOTIONAL UPDATES AND COMMUNICATIONS

 

6.1  Where permitted in our legitimate interest, with your prior consent where required by law or as otherwise permitted by law, we will use your personal information for marketing analysis and to provide you with promotional update communications about our Services.

6.2  You can object to further marketing at any time by checking and updating your contact details within your account, selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to privacy@proxymity.io.

7. WHO WE GIVE YOUR INFORMATION TO

We may disclose your personal data:

7.1  To other companies associated with Proxymity, (which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy). If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.

7.2  To Appropriate third parties including:

1. our business partners, Customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for, such as our analytics or service providers;
2. our auditors, legal advisors and other professional advisors;

7.3  In the event that we sell or buy any business or assets, to the prospective seller or buyer of such business or assets.

7.4  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the company you work for; or to protect the rights, property, or safety of Proxymity, our Customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

 

8. WHERE DO WE STORE YOUR INFORMATION?

 

The disclosures referred to above may involve transferring your personal information overseas. If you are dealing with us within the UK or the European Economic Area, you should be aware that this may include transfers to countries outside the UK or EEA, which do not have similarly strict data privacy laws.  It may also be processed by staff situated outside the UK or EEA who work for us or for one of our suppliers. In those cases, where we transfer personal data to other members of the Proxymity group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements or mechanisms, designed to ensure that your personal information is protected (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission). If you have questions about our international data transfers and the mechanisms in place, you can contact us, using the information in Section 15 below.

9. HOW WE PROTECT YOUR INFORMATION

9.1  Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; the transmission of information via the internet is not completely secure and, therefore, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9.2  Our Services may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

10. HOW LONG WE KEEP YOUR INFORMATION

We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for seven (7) years after that to identify any issues and resolve any legal proceedings. We keep personal data for marketing purposes for two (2) years from the date of our last contact with you or such earlier date if you request we no longer market to you.

11. INDIVIDUALS IN THE U.S.

 

11.1 Processing of Personal Information

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about individuals (where applicable):

Category	Categories of Recipients (as further explained in ‘Who we give your information to’ above
Identifiers such as name, e-mail address, IP address, username, date of birth and unique identifiers	Appropriate Third Parties
Personal information categories listed in the California Customer Records statute such as name, address or telephone number	Appropriate Third Parties
Commercial information such as information about your investment account holdings and your transaction data	Appropriate Third Parties
Internet or other similar network activity such as information regarding your interaction with the Platform	Appropriate Third Parties
Geolocation data such as IP address	Appropriate Third Parties
Professional or employment-related information such as title of profession, employer, professional background	Appropriate Third Parties
Account access credentials* such as credentials allowing access to your account both on the platform and with your intermediary (e.g., broker)	Appropriate Third Parties
The contents of a resident’s mail, email, and text messages*	Appropriate Third Parties

The specific business or commercial purposes for which we collect your personal information and the categories of sources from which we collect your personal information are described in the section above, How we use your information. We only use and disclose sensitive personal information for the permitted purposes specified in the CCPA. The criteria we use to determine how long to retain your personal information is described in the section above, How long we keep your information.

We disclosed personal information over the preceding 12 months for the following business or commercial purposes:

1. to communicate with you, provide you with our Services, to market to you, etc.
2. to maintain and secure your account with us
3. to make or receive (as applicable) payment, for products or services
4. to provide your intermediary (e.g., broker) with information about your investment account holding and transaction data
5. to evaluate your candidacy and process your application for employment.

11.2           Selling and/or Sharing of Personal Information

We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of individuals under 16 years of age.

 

11.3           Your Rights

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

1. Right to Access/Know. You have a right to request that we confirm whether we process information about you and give you access to that information. If you are a California resident, you have a right to request the following information about our collection, use and disclosure of your information over the prior 12 months:

 

• categories of information about you we have collected, disclosed for a business purpose;
• categories of sources from which we collected information about you;
• the business or commercial purposes for collecting information about you;
• categories of third parties to whom the information about you was disclosed for a business purpose; and
  • specific pieces of information about you we have collected.

1. Right to Data Portability. You may also have a right to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment.

 

1. Right to Delete. You have a right to request that we delete information we maintain about you.

 

1. Right to Correct. You have a right to request that we correct inaccurate information we maintain about you.

11.4 You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. Depending on your location, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.  11.5 In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal.

12. INDIVIDUALS IN THE UK AND EEA

If you live in the UK or the EEA, the following sections apply:

12.1   Your Rights

You have the right under certain circumstances:

1. to be provided with a copy of your personal data held by us;
2. to request the rectification or erasure of your personal data held by us;
3. to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
4. to object to the further processing of your personal data, including the right to object to marketing (as mentioned in ‘Our promotional updates and communications’ section;
5. to request that your provided personal data be moved to a third party (i.e. data portability).

12.2   Your right to withdraw consent:

1. Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described in ‘Our promotional updates and communications’ section;

12.3   How to exercise your rights

1. Where we are acting as a data controller, you can exercise the rights listed above at any time by contacting us at privacy@proxymity.io.
2. Where we have collected or received your personal information in our capacity as a service provider to a Customer with which you have a financial account or relationship (including where you work for a customer of that Customer), that company can assist you with requests related to exercising your privacy rights. You can contact such company to learn more about its privacy practices and exercise any of your rights.
3. If we have collected personal information from you directly and you want to make a request to delete it, please email us at privacy@proxymity.io.
4. Unless we are required by law to retain your personal information, where we are acting as a: (i) data controller, we will delete your personal information upon your request; and (ii) data processor, we will delete personal information following instruction from our Customer who will be the data controller.
5. If a request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

13. OUR EXPENSES

We reserve the right to charge you (or your authorized agent, as applicable) a reasonable fee for expenses incurred in connection with your exercise of the rights mentioned above, as permitted by law or regulation.

 

14. CHANGES TO THIS POLICY

 

Any changes we make to our privacy policy in the future will be posted on our website at https://proxymity.io/privacy-terms/ and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on May 23, 2025.

15. CONTACT US

 

Should you have any questions about our privacy practices or this Privacy Policy, please email us at privacy@proxymity.io.