Last Updated: June 13th, 2022
We at Troop, Inc. (“Troop”“we,”“us,”or “our”) know that privacy is very important to you. We have created this privacy notice (the “Privacy Notice”) to describe what kinds of personal information we may obtain through our website located at https://www.troop.com/ (the “Website”), our services that are provided to you through the Website (“Services”) and when you interact with us in any other way.
We explain how we may use and disclose that information, the steps we take to keep it secure, your choices regarding our use of this information, and how you how can contact us if you have any questions about our privacy practices.
Description of Users and Acceptance of Terms
This Privacy Notice applies to visitors to the Website, who view only publicly-available content (“Visitors”) and individuals who have signed-up to access and use our Services (“Registered Users”).
Table of Contents
In the course of operating the Website, providing our Services and/or interacting with you, Troop collects and/or receives the following types of information, which may include personal information.
When you contact us via the “Contact Us ”feature of the Website or in any other manner, you may be required to provide us with personal information about yourself, such as your name, and e-mail address (collectively, the “Contact Information”). We do not collect any Contact Information from you when you use our Website unless you provide us with the Contact Information voluntarily. The Contact Information is used to provide the requested service or information and to contact you for purposes of direct marketing of our current and future products and services.
From time to time, we may ask Registered Users to provide responses to surveys related to their interests, including but not limited to, interests in shareholder activism themes (collectively, “Interest Survey Information”).
From time to time, Registered Users can vote on various items through the Services, including but not limited to, shareholder resolutions, shareholder proposals, shareholder polls and backing shareholder activism campaigns (collectively, the “Voting Information”). Please note that voting through the Services is not the equivalent of voting at a shareholder meeting, or the execution of a proxy, or otherwise voting through a brokerage or some other market intermediary. Thus, votes cast through the Services will not count towards any tally or tabulation for purposes of calculating whether a proposal has or has not been adopted by shareholders at a meeting. Registered User(s) who wish to exercise any applicable shareholder voting rights must do so as set forth in the proxy materials and instructions provided to the Registered User by the applicable company.
In addition to the Contact Information, Account Information, Financial Information, Interest Survey Information, and Voting Information we may collect additional information regarding you and your use of our Website, Services, your interactions with us, as well as information regarding your computer or other devices used to access our Website and Services (collectively, the “Other Information”). Such Other Information may include:
For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics
Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website and the Services.
We use your personal information to provide the Website and the Services to you, and to operate our business. These business services include:
We may share, transfer, or disclose Contact Information, Account Information, Financial Information, Interest Survey Information, Voting Information and Other Information (collectively, the “Information”) if you consent to us doing so, as well as in the following circumstances:
We will take reasonable measures to require that any party receiving any of your personal information from us undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Notice; (ii) not disclose your personal information except with your consent, as permitted by law, or as permitted by this Privacy Notice; and (iii) generally protect the privacy of your personal information.
You may elect to receive SMS text messages from us regarding the Services. These messages may use information automatically collected based on your actions while on our Website and/or our Services and may prompt messaging such as reminders regarding the voting events, and shareholder polls. To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. By opting-in to receive SMS text messages from us, you acknowledge that messaging and data rates may apply depending on your phone service provider. You may opt out of receiving SMS text messages at any time by texting “STOP ”in response to the text messages you receive or by changing your notification and communication preferences in the Services. However, by opting-out of receiving text messages, you may not be able to use full functionality of the Services.
You may voluntarily post and share information including but not limited to, posting comments on specific shareholder proposal pages through various features available from time to time through the Services. None of the information you provide through the use of these features is protected by this Privacy Notice including any personal information. THIS PRIVACY NOTICE DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE VIEWED, COLLECTED, USED, MODIFIED AND/OR DISCLOSED FOR ANY PURPOSE BY US AND OTHER USERS OF THE SERVICES.
We take commercially reasonable steps to protect your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website and the Services may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
We do not knowingly collect personal information from children under the age of 18 through the Website and the Services. If you are under 18, please do not give us any personal information. We encourage parents and legal guardians to monitor their children ’s Internet usage and to help enforce our Privacy Notice by instructing their children to never provide us personal information without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.
You may access, review, delete and make changes to your personal information by following the instructions found on our Website and the Services or by contacting us at firstname.lastname@example.org. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe ”link located on the bottom of any Troop marketing email. You cannot opt out of receiving transactional e-mails related to your account. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. In such case, we will provide you the reason why the modification or removal was not possible.
As discussed above, third parties such as analytics providers may collect information about your online activities over time and across different websites when you access or use the Website and the Services. Currently, various browsers offer a “Do Not Track ”option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track ”settings and/or signals.
If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request ”and providing us with your name and the email address associated with your account. Please note, however, that we do not sell personal data.
The Website and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Website and/or the Services, you consent to any transfer and processing of your personal information in accordance with this Privacy Notice, and you do so at your own risk.
This Privacy Notice is effective as of the date stated at the top of this Privacy Notice. We may update this Privacy Notice from time to time and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Privacy Notice when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. We may require you to affirmatively accept changes to this Privacy Notice prior to next logging-in to your account. By accepting the revised Privacy Notice and/or by accessing the Website and/or the Services after we notify you of changes to this Privacy Notice, you are deemed to have accepted such changes.
If you have any questions or comments about this Privacy Notice, our privacy practices, or if you would like to exercise your rights and choices, please email us at firstname.lastname@example.org.