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California Consumer Privacy Notice

Last updated: May 29, 2026

This California Consumer Privacy Notice ("Notice") supplements the information contained in the Proxy Analytics Privacy Policy and applies solely to natural persons who reside in the State of California ("consumers" or "you"). It explains how we collect, use, disclose, and retain personal information subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA").

1. Scope

Proxy Analytics provides shareholder-engagement and corporate governance analytics to institutional and corporate clients. This Notice describes our handling of information when we act as a "business" under the CCPA (e.g., when you visit our public website, interact with us directly, or where we independently aggregate business intelligence data).

In cases where our subscribing corporate clients enter their own proprietary notes, contacts, or communications into our software platform, Proxy Analytics acts strictly as a "service provider" or "processor" processing information under their direct instructions. This Notice does not apply to data managed by our clients in that capacity.

2. Statutory Exemption for Publicly Available Information

Please note that a significant portion of the data indexed within the Proxy Analytics intelligence platform consists of professional corporate governance histories, institutional voting records, and executive profiles. Under the CCPA (California Civil Code Section 1798.140), "personal information" does not include publicly available information lawfully made available from federal, state, or local government records, such as public filings with the U.S. Securities and Exchange Commission (SEC).

While such public data is strictly exempt from CCPA statutory deletion and access mandates, Proxy Analytics respects the professional privacy of individuals. As a courtesy, we extend a voluntary opt-out mechanism allowing corporate executives and investment professionals to request the removal of their profile information from our active client-facing paid database (see Section 3).

3. Your CCPA Rights

Under the CCPA, California residents have the following rights regarding personal information that is not subject to a statutory exemption:

Right Description
Know/Access Request disclosure of the categories and specific pieces of personal information we have collected about you in the preceding 12 months.
Delete Request deletion of personal information we collected from you.
Correct Request correction of inaccurate personal information.
Opt-Out of Sale/Sharing Direct us not to sell or share your personal information. Proxy Analytics does not sell personal information or share it for cross-context behavioral advertising.
Limit Sensitive PI Limit our use of sensitive personal information to only those purposes permitted by law.
Non-Discrimination Exercise the above rights free from unlawful discrimination.

How to Submit a Request or Profile Opt-Out:
To exercise your statutory CCPA rights, or to submit a voluntary request to have your professional profile removed from our subscription-based governance database, please contact us by:

  • Emailing: privacy@proxy-analytics.com

To protect your data, we will verify your identity before fulfilling any regulatory request. You may also designate an authorized agent to act on your behalf by providing written permission and proof of identity.

4. Personal Information We Collect, Use & Disclose

The table below summarizes the categories of non-exempt personal information we have collected, their sources, business purposes, and disclosures to third parties in the past 12 months.

CCPA Category Examples Sources Business / Commercial Purpose Disclosed To1 Sold or Shared?2
Identifiers Name, business e-mail, IP address, user account credentials Directly from you; automatic device collection Provide platform services, respond to sales inquiries, security logging Service providers (cloud hosting, CRM infrastructure) No
Internet / Network Activity Log files, page views, clickstream data, interaction history Your browser/devices when interacting with our site Site operations, platform analytics, security monitoring Analytics vendors, IT security systems No
Professional or Employment Info Company affiliation, job title, office location Directly from you or your organization Customer support, platform account management, corporate communications CRM provider No
Geolocation (coarse) City/region level location derived from IP address Automatic system tracking Site localization, system security, fraud prevention Security and hosting vendors No
Sensitive PI Multi-factor authentication (MFA) device tokens/identifiers Directly from authorized users of our platform Secure account authentication and platform access control Authentication service providers No

1 Disclosed To: Refers to transfers to vetted service providers or contractors acting on our behalf for essential business purposes (e.g., cloud hosting, analytics, customer support infrastructure). We do not disclose personal information to third parties for their independent commercial purposes.

2 Sale/Share: Under the CCPA, "selling" or "sharing" means transferring personal information to a third party in exchange for monetary consideration or for cross-context behavioral advertising. Proxy Analytics does not sell or share personal information.

5. Retention

We retain personal information only for as long as necessary to fulfill the operational purposes outlined in this Notice, comply with legal or financial obligations, resolve disputes, and enforce our client agreements. Criteria include the active nature of the platform subscription, user account status, and statutory limitation periods.

6. Security Measures

We employ technical, physical, and organizational safeguards that align with industry best practices to protect platform data. Measures include encryption in transit and at rest, multi-factor authentication, strict access controls, and continuous logging and monitoring.

7. Children's Data

Proxy Analytics provides corporate B2B services and does not knowingly collect or solicit information from children under the age of 16. If we learn that a child has provided us with personal information, we will delete it immediately.

8. Changes to This Notice

We may revise this Notice from time to time to reflect operational or regulatory updates. When changes are made, we will update the "Last updated" date at the top of this page.

9. Contact Us

For questions or concerns about this Notice, our data practices, or to submit an opt-out request, please contact our team:

Privacy Team – Proxy Analytics, LLC
Email: privacy@proxy-analytics.com
Phone: (973) 265-4943
Address: 1 Gateway Center, Suite 2600, Newark, NJ 07102

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