IntroductionAt Kingsdale Advisors (“Kingsdale”), we are committed to protecting your privacy rights. The nature of our business involves obtaining certain personal details and financial information related to the securityholders of public companies. Keeping your information confidential is vital to our primary objective of providing the best service possible to our clients
Kingsdale may receive personal information about individuals when we are retained by one of our clients to conduct proxy solicitation or securityholder outreach on their behalf. This personal information may include information regarding how individuals hold their securities, i.e. in registered form or through a company or nominee, and if there are any conditions on the holdings.How does Kingsdale use Personal Information?Kingsdale uses personal information primarily for verifying that the securityholder lists provided to us by a company’s transfer agent or obtained through public source data, to assist you with proxy voting, for proxy solicitation and advisory purposes, and in relation to our depository services. The information we obtain is used in connection with current, publicly announced transactions, or, in certain cases, completed transactions where securityholders have yet to exchange their securities for the consideration that was offered.
We use this personal information with utmost respect and appropriate safeguards. Personal information is not used or transmitted to anyone else for any other purpose but those listed above. Personal information will only be used or disclosed for purposes that a reasonable person would consider appropriate in our business.
WWe have internal policies and procedures regarding the use, disclosure and retention of personal information. These policies and procedures provide guidelines for how we archive and ultimately destroy records which contain personal information. In discharging our role on behalf of our clients, we are also required to comply with statutory and regulatory record-keeping requirements. As such, in order to be able to respond to issues which may arise at a future date, we may be required to keep certain records for extended lengths of time. However, these records are kept in accordance with our privacy procedures, remain confidential and are held in a secure location.How does Kingsdale Collect Personal Information?Typically personal information will come either from individuals directly or from third parties authorized by individuals, such as from the company in which they hold securities, that company’s transfer agent, their legal counsel or financial intermediaries acting on their behalf.
Kingsdale does not collect your information for any purpose other than those identified in this Policy. Personal information may be collected to service your account, to act on your transaction instructions or to contact you on behalf of an issuer.
Ordinarily we will not use or disclose your personal information other than for the purposes outlined above. However, in the course of conducting our business and in order to carry out certain lawful purposes, other parties, such as affiliated companies, mailing agents and other suppliers or agents who facilitate our services may require access to your personal information. In addition, if you are a securityholder of an issuer, your information is made available to the issuer or the issuer's agents.Why do we Collect Personal Information?We collect, use and disclose personal information about you so that we can:
- establish your identity;
- protect you and us from error and fraud; and
- comply with legal and regulatory requirements.
It is important that you are made aware of the purpose behind our use of personal information. Depending on the service provided, this purpose is communicated to you verbally or in writing. Often, the reasons are obvious; as when you provide your personal information to us in order to obtain our assistance in voting your securities. In performing our depository services or in asset reclamations, we may also use information about you to locate you, correct our records for