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Privacy Policy


Last Updated March 2024

Introduction

Equilar respects your privacy and is committed to protecting it through our compliance with this policy. Equilar reserves the right to modify this Privacy Policy at any time, so we kindly ask that all users (“You”) of our website, located at www.equilar.com (the “Website”) and the products and services available through the Website (the “Products” and “Services”) review our Privacy Policy periodically. If You object to any of our changes, You may deactivate Your account at any time. By continuing to use the Website, Products, and Services, You are consenting to our Privacy Policy and any changes made to our Privacy Policy.

Additionally, when You visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about You, including by association with Your email or address. We (or service providers on our behalf) may then send communications and marketing to these email or addresses. You may opt out of receiving this advertising by visiting app.retention.com/optout.

1. Information Collected by Equilar and How it is Used

Here are the types of data that Equilar may collect:

  1. Information You provide by filling in forms on our Website or through our Products and Services. This includes information provided at the time of registering to use our Website, Products, or Services, or posting material. We may also ask You for information when you report a problem with our Website, Products, or Services.

  2. Records and copies of your correspondence (including email addresses), if you contact us.

  3. Your responses to surveys that we might ask you to complete for research purposes (“Surveys”).

  4. Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

  5. Your search queries on the Website, Products, and Services.

  6. Names of business executives

  7. Job titles of business executives

  8. Job history of business executives (company name and dates)

  9. The age of business executive

  10. Gender (self-reported or publicly disclosed in SEC filings).

  11. Sexual Orientation (self-reported)

  12. Ethnicity (self-reported) to identify diverse candidates for business purposes.

  13. Institutions of higher learning that an executive has attended

  14. Facial image of business executives

  15. Biography of business executives

  16. Compensation data of business executives

  17. A password to access our Products and Services

Equilar defines business executives as individuals that hold top managerial or board positions in for-profit and/or nonprofit organizations. The vast majority of the data we collect is obtained from public sources such as regulatory filings and various governmental forms. Of the data gathered from public sources, we provide the executive with the opportunity to correct data that are factually inaccurate. On occasion, we collect data that are not obtained from publicly accessible sources. These non-public data are provided to us by the executive. We do not publish or disclose any personally identifiable, non-public data unless we have obtained the express consent of the owner to disclose the information.

The data we collect and process will depend on the Equilar Products and Services a particular client uses. We may collect:

  • Publicly available data from sources such as SEC filings, company and non-profit websites that are accessible without login, IRS Form 990 information, and Department of Labor Form 5500 data to provide information related to corporate executives and board members (“Public Profiles”);

    • This public data is utilized to create and update executives’ profiles
  • Compensation data provided to us by our Survey participant subscribers for their most senior executives (generally the top 20 to 25) that is included as part of the summary statistics on the pay of senior executives (“Compensation Data”). The methodology and reporting of Compensation Data in our Survey product are carried out in accordance with the “Antitrust Safety Zone Guidelines” issued by the Department of Justice and access is limited solely to our Survey participant subscribers.

We also collect certain personal information from our subscribers in the following ways:

  1. Registration. In order to become a user of one of our online Products or Services, You must provide us with Your name and email address. We will not rent, sell, barter, or otherwise share Your email address with or to any third party, except as expressly set forth in this privacy policy. Only authorized Equilar employees have access to our email databases. If you attend one of our events, we may provide some of Your information to the sponsors of the events, and our sponsors may send you informational or marketing communications. We never use Your data, including Your email address, for any purpose other than to provide You with the Products and Services as well as to send You opt-in email alerts and occasional informational emails relating to the Products and Services.

  2. Sharing Additional Information with Authorized Third Parties. Some of our Products allow You to share information, such as personal contacts, informational profiles, white papers, presentations, etc. on the Website. To facilitate sharing this information, You must provide Equilar with the authorized third party’s name and email address. This information will only be used to share the information You have expressly requested to be shared. It will not be used by us for any other purpose nor will it be shared with any unauthorized third party for any reason unless required by law. You may also choose to upload data about Your contacts to Equilar. This information will be used exclusively to match Your contacts to people with existing public profiles on the Website, Products, or Services (“Public Profiles”). After this matching process is complete, all uploaded third-party contact information is deleted from Equilar’s systems. Communications You initiate through Equilar with authorized third parties may list Your primary email address and name in the header of the message.

  3. Additional information. Information You provide to Equilar may reveal, or allow others to identify, Your nationality, ethnic origin, gender, age, and other aspects of Your life. Supplying information to Equilar, including any information deemed “sensitive” by applicable law, is entirely voluntary on Your part. You have the right to withdraw Your consent to Equilar’s collection and processing of Your information at any time, in accordance with the terms of this Privacy Policy, by changing Your settings, or by closing Your account. Note that Your withdrawal of consent will not be retroactive.

  4. Cookies. We use cookies and web log files to track site usage and trends, to improve the quality of our Products and Services as well as to customize Your experience. A cookie is a tiny data file that resides on Your computer, mobile phone, or other devices, and allows us to recognize You as a visitor when You return to the Equilar website using the same computer and web browser. One type of cookie, known as a “persistent” cookie, is set once You’ve logged in to Your Equilar account. The next time You visit the Equilar website, the persistent cookie will allow us to recognize You as an existing user so You will not need to log in before using the Products and Services. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the Equilar website. Session cookies expire after a short time or when You close Your web browser. We do not use flash cookies for advertising purposes. You can remove or block cookies at any time by using the settings in Your browser. But in doing so You may directly impact Your ability to use the Products and Services. Equilar may also use cookie-equivalent technology for the limited purpose of enhancing the security of the Products and Services. For additional information on the types of cookies we use, please contact our Data Protection Officer: dataprotectionofficer@equilar.com.

  5. Web Beacons/GIFs. We may employ a software technology called “clear GIFs” (a.k.a. Web Beacons/Web Bugs) that help us better manage content on our site by informing us what content is effective. Specifically, clear GIFs are tiny graphics with a unique identifier, which we might use in combination with cookies to measure the number of unique views of content and depth of interaction with content when using the Products and Services. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs are embedded on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear GIF to Your personal account information. We may use clear GIFs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of our email communications. You may opt-out of these emails by clicking on the “unsubscribe” link contained near the bottom of our emails.

  6. Links to Third Party Sites. The Website, Products, and Services may contain links that allow You to visit other websites (“Third Party Sites”). Any link provided to Third Party Sites is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of its privacy or information security policies or practices. We do not exercise control over Third Party Sites or their use of any information that You choose to submit to them or have us transmit on Your behalf. These other websites may place their own cookies or other files on Your computer, collect data or solicit personal information from You. Other sites follow different rules regarding the use or disclosure of the personal information You submit to them. We encourage You to read the privacy policies or statements of the other websites You visit.

  7. Log Files, IP Addresses, and Information About Your Computer and Mobile Device.. Due to the communications standards on the Internet, when You visit the Equilar website, we occasionally, automatically receive the URL of the site from which You came. The link between Your IP address and Your personally identifiable information is not shared with third parties without Your permission, except as described in the Compliance with Legal Process section below.

  8. Excluded Data. Equilar does not collect the following types of data:

    1. Family information

    2. Home addresses

    3. Home phone numbers

    4. Credit information

    5. Social security numbers or any unique identifier of individuals issued by government agencies.

    6. Personal information of children under the age of 13. Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website, Products, or Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to us, make any purchases from us, use any of the interactive or public comment features of this Website, Products, or Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at dataprotectionofficer@equilar.com.

2. Additional Uses of Your Information

  1. Equilar Communications. We will communicate with You through email, notices posted on the Website, or other means available through the Products or Services. We may send You emails that inform users about the features of the Products or Services, service messages relating to the functioning of the Products or Services, as well as promotional information.

  2. Changing Preferences. You can change Your email and contact preferences at any time by logging into Your account and changing the settings related to Your email notification choices. Please note that You cannot opt-out of service messages from Equilar. Also, if we send communications to You via the carrier service with which You have a mobile communications subscription or otherwise have access, You understand You will pay any service fees associated with Your receipt of messages on Your mobile device.

  3. User Communications. Communications that You initiate through the Website will list Your name as the initiator but will not include Your personal email address. Your email address will only be shared with another Equilar customer if both of You have indicated that You would like to establish contact with each other.

  4. Sharing Information with Third Parties. Equilar takes the privacy of our customers very seriously, and we do not sell, rent, barter, share, or otherwise provide Your personally identifiable information to third parties except as described in this policy. We will also not share other personal information without Your explicit consent or to carry out Your instructions unless disclosure is reasonably necessary, in our opinion, to: (1) comply with legal process; (2) enforce this Privacy Policy; (3) respond to claims of a violation of the rights of third parties; (4) respond to customer service inquiries; or (5) protect the rights, property, or personal safety of Equilar or its customers.

  5. Anonymous Data. We may provide aggregated anonymous data about the usage of the Products and Services to third parties for purposes that we deem, in our sole discretion, to be appropriate, including to prospective sponsors of Equilar events.

  6. Compliance with Legal Process. We may disclose personal information, profile information, and/or information about Your activities as an Equilar user when required by subpoena or other legal process, or if Equilar has a good faith belief that disclosure is necessary to (a) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) to enforce the Equilar Terms of Service, to investigate and defend ourselves against any third-party claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property or personal safety of Equilar, our employees, our customers, or others.

  7. Disclosures to Others as the Result of a Change in Control or Sale of Equilar. We may also disclose Your personal information and other information You provide to another third party as part of a sale or change in control of Equilar. Any third party to which Equilar transfers or sells a controlling interest in Equilar’s assets will have the right to continue to use the personal and other information that You provide to us under the terms and conditions of our Privacy Policy.

3. Choices About How We Use and Disclose Your Information

  1. Accessing and Changing Your Account Information. Please note that Equilar retains sole discretion to determine what information is contained in any Public Profile. A Public Profile is a profile of an individual that has been constructed by Equilar from data obtained from publicly available sources. You can review any additional information You provided to us and make any desired changes to that information, or to the settings for Your Equilar account including Your email and contact preferences, at any time by logging into Your account on the Website. Please be aware that even after Your request for a change is processed, Equilar may, for a time, retain residual information about You in its backup and/or archival copies of its database.

  2. Default Settings. In order to maximize the benefit of the Products and Services, we have established reasonable default settings. Because You may use and interact with Equilar in a variety of ways, and because those uses may change over time, we designed our default settings to provide You with maximum control over the information You share. However, we encourage You to review Your account settings periodically and adjust them in accordance with Your preferences.

  3. Closing Your Account. You can close Your account through the Website. If You close Your account, we may retain certain data contributed by You if Equilar believes it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, including, but not limited to, analysis of aggregated, non-personally identifiable data, account recovery, or if required by law.

  4. Data Retention. Subject to applicable laws and this Privacy Policy, Equilar will retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms Of Service.

4. Security

In order to help secure Your personal information, access to Your data on Equilar is password protected. Sensitive data (such as Your password information) is protected by SSL encryption when it is exchanged between Your web browser and the Equilar website. To protect any data You store on our servers, Equilar also regularly audits its system for possible vulnerabilities and attacks, and we use a tier-one, secured-access data center. However, since the Internet is not a 100% secure environment, we cannot guarantee the security of any information You transmit to Equilar. There is no guarantee that the information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical or managerial safeguards. It is Your responsibility to protect the security of Your login information. Please note that emails and similar means of communication with other users are not encrypted, and we strongly advise You not to communicate any confidential or sensitive information through these means. A copy of Equilar’s IT and Data Security Policy covering details regarding organizational, application level and physical security measures is available upon request from info@equilar.com.

5. Privacy of Your Information in Automatic Contact Sync

Equilar takes your privacy and the security of Your data seriously. Equilar will not sell, rent, barter, share or otherwise provide Your personally identifiable information with anyone. Equilar will not make Your information public in any way, shape or form. (Section 2 of Privacy Policy)

Our commitment to privacy extends to the Contact Sync feature, which helps you leverage information from Your address books, emails, and calendars via our website and mobile app. Equilar uses the following technologies to ensure we are compliant with ensuring your privacy with Contact Sync:

  • OAuth 2. 0 (Open Authorization) is the industry standard protocol for authorization – Equilar uses the latest technology for Contact Sync which prevents access to Your credentials

  • Encryption In-Transit - all communications between our services and Your devices use strong 256 bit encryption(HTTPS, SSL, TLS) to ensure sensitive data cannot be read, even if the transmission is intercepted.

Equilar does not store Your account credentials such as email address and password. When you use Contact Sync, only you will be able to view the information in Your Contact Sync profiles.

6. General Data Protection Regulation

Equilar services are operated from data centers in the state of Oregon in the United States of America. All database and service information is stored on these servers. For emergency and business continuity purposes, a mirror is maintained in the state of South Carolina.

Equilar complies with the General Data Protection Regulation pertaining to residents of the European Union.

  • You have the right to access and get a copy of your personal data that we have on file at any time.

  • You have the right to withdraw consent to use your personal data where applicable at any time.

  • You have the right to request deletion of your personal data or restrict how it is used.

  • You have the right to object to the processing of your personal data for certain purposes.

  • If you would like to make any of these requests or inquire more about Equilar’s GDPR compliance, please contact the Data Protection Officer at dataprotectionofficer@equilar.com.

7. California Residents

Starting January 1, 2020, under the California Consumer Privacy Act (the CCPA) residents of the state of California have the following rights:

You have the “Right to Know” or the “Right to Access Information About Collection, Disclosure and Sale of your Personal Information” over the past 12 months. You may contact dataprotectionofficer@equilar.com to request your right to information about collection, disclosure and sale of your personal information.  The information you provide when contacting Equilar will only be used to fulfill your CCPA request.

The “Right to Know” or the “Right to Information About Collection, Disclosure and Sale of your Personal Information” gives you the right to request the following information: 

  • Categories of personal information Equilar has collected about you;

  • Categories of sources from which the personal information was collected;

  • Categories of your personal information that Equilar sold or disclosed for a business purpose;

  • Categories of third parties to whom the personal information was sold or disclosed for a business purpose;

  • The business or commercial purpose for collecting or selling personal information; and

  • The specific pieces of personal information that Equilar has about you

You have the Right to Deletion of information you have shared with us, subject to certain exceptions. You may contact dataprotectionofficer@equilar.com to request the deletion of the information you have shared with us.  The information you provide will only be used to fulfill your CCPA request.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You have the Right to Opt Out of the Sale of Your Personal Information, unless such personal information was collected from a government source.  You may contact dataprotectionofficer@equilar.com to request to opt out of the sale of your personal information. The information you provide will only be used to fulfill your CCPA request.

You also have a Right Not to be Discriminated Against for exercising your CCPA rights. You do not need to request this right, this a is a right we will always give you in regard to any CCPA rights request. 

If you would like to exercise your CCPA rights over the phone, please call us at 1-650-241-6600 and clearly state that you are a resident of the state of California and wish to exercise your CCPA rights. We will ask for additional information to verify your identity.

An authorized agent may make a CCPA request on your behalf.  The authorized agent will need to provide the information necessary to confirm your identity, as well as written and signed permission to act on your behalf.  An “authorized agent” must also be a natural person or business registered with the Secretary of State in California.

We reserve the right to use a third party to verify your identity and this third party may require additional information for verification purposes. The data you provide will only be used to fulfill your CCPA request. 

Please see Section 1 above for the categories of personal information about California consumers that we have collected, sold and disclosed for a business purpose over the past 12 months.

8. How to Contact Us

If You have questions or comments about this Privacy Policy, please contact: dataprotectionofficer@equilar.com or:

Equilar, Inc.
Attn: Equilar Privacy Policy Issues
1100 Marshall St.
Redwood City, CA 94063 USA