This Privacy Policy describes how Stakeholder Labs, through its Roundtable product (“we” or “Roundtable”) collects, uses, shares and protects personal information when you interact with our websites (www.roundtable.xyz) or emails we send, social media accounts, and online services (our “Services”).

This Privacy Policy explains the following:

• How We Work
• The Personal Information We Collect
• Online User Activity, Cookies and Information Collected by Other Automated Means
• How We Use Your Personal Information
• How We Share Your Personal Information
• How We Protect and Store Your Personal Information
• Retention of Your Personal Information
• Your Privacy Options
• Updates to this Privacy Policy
• Additional Notices
  • California Residents
  • Virginia, Colorado, and Connecticut Residents
  • California Job Candidates

Please note that this Privacy Policy does not apply to non-Roundtable websites or services that state that they are offered under a different privacy policy. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

For questions about our privacy practices, contact us at: support@stakeholderlabs.com

1. How We Work

Roundtable is a platform that facilitates connections between investors and the companies in which they invest. Roundtable does this by enabling companies to verify individual investor ownership of company shares and offer unique shareholder rewards.

We partner with companies who administer shareholder rewards programs to provide benefits and other special promotions to individuals who own stock in the company (our “Rewards Partners”). Our Rewards Partners engage us to facilitate your engagement in their programs, including by verifying your ownership of company shares so that you can participate in their shareholder rewards programs. We also enable investors to interact with other companies with whom they own shares.

Your participation in a rewards program results in us collecting information about you, potentially from a number of sources, and sharing the information with our Rewards Partners. We partner with a company called Plaid to facilitate the collection of information from your financial institution to verify individual investor ownership, and we share this information with the Rewards Partners when you choose to participate in their rewards programs. We may also collect information about you, your interests, and preferences, and use that information to develop shareholder insights that we share with Rewards Partners. This Policy explains our data processing activities in more detail, and provides information about the choices you have regarding how we collect, use, and share your information.

2. The Personal Information We Collect

Depending on the nature of your interaction with Roundtable, we may collect personal information as follows:

Directly from you, when you provide information to us or interact with us:

• Contact information such as your name, e-mail address, and any other information you choose to include when you communicate with us via e-mail or other channels.
• Any other information you choose to provide, such as inquiries and feedback.

Automatically from you, when you utilize or interact with our Services:

• Device information and online user activity when you utilize our technology platforms, as described in Section 2 below.

From third parties:

• Information about your financial portfolio, such as the number of shares you own in certain companies, date of share purchase and sale, and other general brokerage information (“Financial Information”), through our partnership with Plaid, who retrieves this information from your financial institution. When you authorize collection of Financial Information, Plaid may retain a copy and use the information as described in its Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy. You may be able to control what information Plaid collects about you and how it uses your information by visiting https://my.plaid.com/. Information about your interactions with our Rewards Partners, such as whether you have purchased goods and services from the companies you hold shares in.
• Information about you, your interests, and preferences (“Preference Information”) from Rewards Partners, third party sources that provide consumer data, social networks, and other sources of publicly available data.

3. Online User Activity, Cookies and Information Collected by Other Automated Means

When you interact with the Services, certain information about your use of our Services is automatically collected. This includes:

• Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses).
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device's telephone number).
• Location information where you choose to provide the website with access to information about your device’s location.

Much of this information is collected through cookies, web beacons, and other tracking technologies, which may be operated by our partners who assist us in collecting information about usage of the Services, serving ads, or providing other services to you. For example, we use Google Analytics to collect usage details. You can learn more about privacy and Google Analytics by visiting https://support.google.com/analytics/answer/6004245, and opt out of collection of your data by using the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout. We may also use cookies set by other third-party services.

You may be able to opt out tracking by cookies or control how information collected by cookies is used via a number of means, as described in Section 7 below.

Your browser or device may include “Do Not Track” functionality; please note that we do not respond to such signals. However, our website is designed to honor Global Privacy Control signals.

4. How We Use Your Personal Information

We use the personal information we collect from you for the following purposes:

• When you elect to enroll in a Reward Partner’s shareholder rewards program, we will facilitate the process to verify that you own shares in that company and create shareholder insights so that our Rewards Partners can better engage with their shareholders.
• Respond to your requests, questions and comments, including on behalf of our Rewards Partners, and provide customer support.
• Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns.
• Interact with you, including to notify you about important changes to this Privacy Policy, our Terms or other policies.
• Manage, operate, and improve the Services and grow our business, including understanding our user base and diagnose or fix technology problems.
• Comply with legal requirements and industry standards, detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and protect the rights of Roundtable, you, or others.

We may use and share information in an aggregated or de-identified manner at our discretion, including for research, analysis, modeling, marketing, and improvement of our Services.

5. How We Share Your Personal Information

• Rewards Partners. If you elect to enroll in a Reward Partner’s shareholder rewards program and authorize us to verify your ownership of shares in that company, we will collect and share your Financial Information with our Rewards Partners. We may also combine your Financial Information with Preference Information to develop shareholder insights, and disclose those insights with our Rewards Partners. We may use your information to create insights for other companies whose stock you hold; however, the insights will not identify you individually, and we will not disclose your Financial Information to that Rewards Partner unless you choose to enroll in that program.
• Service Providers. We may share your information with service providers that we believe need the information to perform a technology, business, or other professional function for us such as IT services, maintenance and hosting of our Services, accounting, auditing, and tax services, and other professional services.
• Analytics Partners. We partner with analytics providers, who collect information via tracking technologies on our websites to assist us with measuring visits and traffic on our websites so we can measure and improve the performance of the sites.
• Social Media Platforms. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.
• Corporate Event. We reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
• Legal. We share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third parties, as permitted by law and without your consent when it is necessary to protect our customers, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies.

6. How We Protect and Store Your Personal Information

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries.

7. Retention of Your Personal Information

We will retain your personal information for as long as is necessary to complete the purposes for which it was collected, or as may be required by law.

California law requires us to provide information regarding the criteria we use to determine the length of time for which we retain personal information. We utilize the following criteria to determine the length of time for which we retain information:

• The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes.
• Whether we are required to retain the information type in order to comply with legal obligations or contractual commitments, to defend against potential legal claims, or as otherwise necessary to investigate theft or other activities potentially in violation of our policies and procedures applicable to you or against the law, to ensure a secure online environment, or to protect health and safety.
• The privacy impact of ongoing retention on the consumer.
• The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

Individual pieces of personal information may exist in different systems that are used for different business or legal purposes. A different maximum retention period may apply to each use case of the information. Certain individual pieces of information may also be stored in combination with other individual pieces of information, and the maximum retention period may be determined by the purpose for which that information set is used.

8. Your Privacy Options

You may have certain choices when it comes to how we collect and use your personal information:

• Disclosure to Rewards Partners. You may opt-out of future disclosures of your information to companies that administer shareholder rewards programs by visiting Your Privacy Choices.
• Collection and Disclosure of your Financial Information. When you authorize us to collect your Financial Information, the information is refreshed regularly to allow us to confirm that you remain a shareholder of a particular company. You may stop future updates of your information by visiting Your Privacy Choices. You will also need to change your preferences with Plaid at https://my.plaid.com/ if you would like to prevent Plaid from accessing your information in the future.
• Online Activity Tracking and Interest-Based Advertising. You have several options to either prevent our collection of information regarding your online activity.
  • You can opt out or set preferences regarding cookies when a device you utilize visits the Services, by visiting Your Privacy Choices to access our cookie management tool. Please note that you will need to set preferences on each device you use to visit the Services.
  • If your browser offers you the ability to use the Global Privacy Control (GPC) to communicate your privacy preferences to us, we honor such signals.
  • You may also modify your browser setting to disable or reject cookies across the internet; but if you do so, some features of our website or Services may not function properly or be available. If you are visiting the Services from a mobile device, the operating system of the device may offer you options regarding how the device collects and uses your information for interest-based advertising. Please visit https://thenai.org/opt-out/mobile-opt-out/ for more information.
• Collection and Disclosure of Information by Consumer Data Providers: When you opt out of our use or sharing of your information, it does not opt you out of the use or sharing by other companies, including “data brokers” who may provide us with information. To learn more about data brokers generally, visit data broker registries created by California (https://oag.ca.gov/data-brokers) and Vermont (https://sos.vermont.gov/corporations/other-services/data-brokers/).

Please note that if you wish to discontinue your participation in any Shareholder Rewards Programs that you have enrolled in, you will need to contact the Rewards Partner directly.

9. Updates to This Privacy Policy

We may make changes to this Policy from time to time. The “Effective Date” at the top of this page indicates when this Privacy Policy was last revised. We may also notify you in other ways from time to time about the collection, use, and disclosure of your personal information described in this Policy.

10. Additional Notices

CALIFORNIA RESIDENTS

California law provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” rights to access, delete, correct certain Personal Information we collect about them, restrict us from “selling” or “sharing” certain Personal Information, and limit our use of Sensitive Personal Information, as defined by the law and described in the categories below. These rights apply to all residents of CA, regardless of whether you are a customer, website visitor, business contact, or member of our workforce. As a California resident, you have a right not to receive discriminatory treatment for the exercise of your privacy rights.

If you are a customer, website visitor, or business contact, please review this notice to learn more about your rights. If you are a candidate for employment, please see our supplemental California Notice of Collection for Job Candidates below.

Collection, Use, and Retention

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. The categories we use below to describe the information are those enumerated in the CCPA.

The following chart describes our practices with regard to the collection, use, and retention of your Personal Information. The categories we use to describe the information are those listed in the CCPA. Certain Personal information may fall into multiple categories, and in some circumstances, how we use and how long we keep the information within each category will vary.

The examples of Personal Information listed below are illustrative and do not represent a complete description of the information we process.

Sale, Sharing, and Other Disclosure of Personal Information

Any category of Personal Information listed in the chart above may be disclosed for a business purpose to service providers and contractors, which are companies or individuals that we engage to conduct activities on our behalf. Service providers and contractors are restricted from using personal information for any purpose not related to our engagement.

California law also requires us to provide you with information regarding the parties to whom we “sell” or “share” your information, and the parties to who we disclose your information for a business purpose. Under the CCPA, a business “sells” Personal Information when it discloses Personal Information to a company for monetary or other benefit. A company may be considered a third party either because the purpose for its sharing of Personal Information is not for an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for other purposes.

We sell or share your information as follows:

• Personal Identifiers: Rewards Partners
• Personal information categories listed in the California Customer Records statute: Rewards Partners
• Commercial Information: Rewards Partners
• Internet or other similar network activity: Rewards Partners
• Inferences drawn from other personal information: Rewards Partners

We may disclose your information in other ways that are not considered a “sale” under the law. Please see “How We Share Personal Information” above for more information about how we share your information.

Right to Know and Request Access to, Correction of, and Deletion of Personal Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You also have the right to request we correct inaccurate Personal Information and to request, in certain circumstances, that we delete any Personal Information that we have collected directly from you.

You may submit a request to exercise your rights to delete your Personal Information by filling out a Privacy Request Form available at https://forms.gle/H5tq88Pbe8jdxBTc7. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means.

In order to process your request, we must verify your request. We do this by asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email account stated in the request.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Opt Out of Sale of Personal Information to Third Parties

You have the right to opt out of our sale of your Personal Information to third parties. To view our Notice of Right to Opt Out of Sale/Sharing and exercise your right, please visit our Your Privacy Choices page. Please note that your right to opt out does not apply to our sharing of personal information with Service Providers, as described above.

Right to Limit Use of Sensitive Personal Information

You have the right to request that we limit use of your sensitive personal information to certain purposes allowed by law. However, we do not process your sensitive personal information in circumstances that would be subject to the right to limit.

VIRGINIA, COLORADO, AND CONNECTICUT RESIDENTS

Laws in Virginia, Colorado, and Connecticut provide residents of these states with rights to access, delete, and correct certain “Personal Data” we collect about them, as well as to restrict the use of that Personal Data for targeted advertising, restrict the “sale” of that Personal Data, and control our use of Personal Data considered sensitive. If you are a resident of any of these states, you also have a right not to receive discriminatory treatment for the exercise of your privacy rights.

You or your authorized agent may submit a request to exercise your access, deletion, and correction rights by filling out a Privacy Request Form available at https://forms.gle/H5tq88Pbe8jdxBTc7. To opt out of the sale or sharing of Personal Data, please visit our Your Privacy Choices page. If we deny your request, you have the right to appeal our decision. You may do so by emailing us at support@stakeholderlabs.com.

CALIFORNIA JOB CANDIDATES

Collection, Use, and Retention

When you apply for a job with Roundtable, information may be collected about you in multiple ways: you may provide it to us in connection with your application; we may make observations in the application process or collect information from public information sources; or you may authorize us to collect information from other sources, such as a former employer or reference.

The following table describes our practices with regard to information submitted in the job application process. If you use our website in the job application process, additional information may be automatically collected, as described above.

We also collect any other information you elect to provide to us, including information from social media sites if you choose to link your application to a social media page.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Sale, Sharing, and Other Disclosure of Personal Information

Any category of Personal Information listed in the chart above may be disclosed for a business purpose to service providers and contractors, which are companies or individuals that we engage to conduct activities on our behalf. Service providers and contractors are restricted from using personal information for any purpose not related to our engagement.

California law also requires us to provide you with information regarding the parties to whom we “sell” or “share” your information, and the parties to who we disclose your information for a business purpose. Under the CCPA, a business “sells” Personal Information when it discloses Personal Information to a company for monetary or other benefit. A company may be considered a third party either because the purpose for its sharing of Personal Information is not for an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for other purposes. We do not sell personal information relating to our job applicants.

We may disclose your information in other ways that are not considered sales under the law. Please see “Our Disclosure of Personal Information” above for more information about how we share your information.

Right to Know and Request Access to and Deletion of Personal Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You also have the right to request we correct inaccurate Personal Information and to request, in certain circumstances, that we delete any Personal Information that we have collected directly from you.

You may submit a request to exercise your rights to delete your Personal Information by filling out a Privacy Request Form available at https://forms.gle/H5tq88Pbe8jdxBTc7. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means.

In order to process your request, we must verify your request. We do this by asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email account stated in the request.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Opt Out of Sale of Personal Information to Third Parties

You have the right to opt out of our sale of your Personal Information to third parties. However, we do not sell personal information relating to our job applicants.

Right to Limit Use of Sensitive Personal Information

You have the right to request that we limit use of your sensitive personal information to certain purposes allowed by law. However, we do not process your sensitive personal information in circumstances that would be subject to the right to limit.