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Privacy Policy

Last Updated: August 1st, 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 (“Services”) that are provided to you through the Website and mobile application, which is accessible through tablets, smart phones, and other devices (the “App”), 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”).

By visiting our Website, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

By clicking “SUBMIT,” when you sign up to access and use the Services, each Registered User is agreeing to the terms of this Privacy Policy, and the accompanying Terms of Use.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

Table of Contents

1. Information We CollectA) Contact InformationB) Account InformationC) Financial InformationD) Interest Survey InformationE) Voting InformationF) Other Information2. Information Collected/Received From Third-Party Sources3. How We Use Your Information4. How We Share Your Information5. SMS Text Messages6. Information Collected Through The Services That Is Not Covered By This Privacy Notice7. How We Protect Your Information8. Children’s Information9. External Websites10. Accessing And Modifying Information And Communication Preferences11. Do Not Track12. Notice To Nevada Residents13. Important Notice To Non-U.S. Residents14. Updates To This Privacy Notice15. How To Contact Us
1. Information We Collect
In the course of operating the Website and/or the App, providing our Services and/or interacting with you, Troop collects and/or receives the following types of information, which may include personal information.
A. Contact 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, phone number, and email 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.
B. Account Information
In order to access and use our Services, you will have to create an account as a Registered User. In connection with opening an account, we collect account credentials such as name, e-mail address, user handle, and any other registration information that is required to complete your registration (collectively, “Account Information”). We use the Account Information to process the creation of your account, including to verify your identity, and to manage your account. Please note that your user handle will be visible to other Registered Users.

If you would like to use the App, you will need to download the App from the Apple, Android or any other app store through which the App is made available to you.
C. Financial Information
In order to access and use our Services, you will have to link your brokerage accounts to your Troop account. When you connect your brokerage accounts to your Troop account, we collect financial information about your investments, including but not limited to, stock holdings, stock transactions and quantities of equities you own (collectively, the “Financial Information”). The Financial Information is used to verify your ownership of certain securities. Troop currently uses Plaid Technologies, Inc. (“Plaid”), a third party service provider, to retrieve information from your linked brokerage accounts. We do not see or store your bank credentials, cost basis or cash in your brokerage accounts. By accessing and using the Services, you acknowledge and agree that the terms of Plaid’s privacy policy (https://plaid.com/legal/) will govern Plaid's collection and use of such information, and you consent to Plaid's privacy policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide its services.
D. Interest Survey Information
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”).
E. Voting 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.
F. Other Information
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, App, Services, your interactions with us, as well as information regarding your computer or other devices used to access our Website, App and Services (collectively, the “Other Information”). Such Other Information may include:
  1. Information obtained from your online activity.
    Information that we automatically collect when you use the Website, the App and/or the Services, such as (i) information about the device from which you access the Website, the App and/or the Services (i.e., the type of device, the advertising identifier (“IDFA” or “AdID”), the operating system and version (for example iOS, Android orWindows), your carrier and network type (WiFi, 3G, 4G, LTE); (ii) your IP addresses (which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device); (iii) browser type and language; (iv) referring and exit pages and URLs; (v)date and time; (vi) amount of time spent on particular pages; (vii) what features of the Website, theApp and/or the Services you use or visit; and (viii) similar information concerning your use of theWebsite, the App and/or the Services.
  2. Information we collect automatically through cookies, and similar technology.
    Like mostonline services, we automatically receive standard technical information when you connect withthe Website, the App and/or the Services. We collect this information through browser cookies, pixels, web server logs, web beacons, and similar technologies. These features enable us to personalize your experience on the Website, the App and the Services, understand how you use them, maintain a persistent session, and improve and further develop the Website, the App and the Services. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use cookies to help us collectOther Information and to enhance your experience using the Website, the App and the Services. Specifically, we use cookies to authenticate users, personalize your experience when using theWebsite, the App and the Services, analyze which features of the Website, the App and the Services you use most frequently, and measure and optimize advertising and promotional effectiveness. Todo this, we may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, the Website, the App and the Services may not function properly.
  3. Information obtained from third-party analytics services.
    We may use third-party analytics services (such as Google Analytics) to evaluate your use of the Website, the App and the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Website, the App and the Services and mobile and internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing the Website, the App and/or using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Notice.

    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, the App and the Services.
2. Information Collected/Received From Third-Party Sources
We may also collect information about you from third-party data sources, such as brokers, banks and government databases, and combine it with data we collect from you. All information we collect and/or receive from such third-party sources is collectively called as “Third-Party Information.”For example, we use Plaid to gather your data from financial institutions. By using our Services, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal).
3. How We Use Your Information
We use your personal information to provide the Website, the App and the Services to you, and to operate our business. These business services include:
  1. Service-Related Usage:
    We use the Contact Information, Account Information, Financial Information, Interest Survey Information, Voting Information, Third-Party Information and the Other Information to provide and support the Website, the App and the Services, such as informing you about campaigns related to target companies in which you invest or related to issues that may be of interest to you, communicating with you and other customers, managing user accounts, providing customer service, informing you about our products and services, and maintaining our systems.
  2. Analyzing and Improving the Website and the Services:
    We may run calculations, aggregate, normalize, clean, and make derivative works of the information obtained about you in order to:
    • Understand and analyze usage trends and preferences;
    • Monitor and analyze the effectiveness of the Website, the App and the Services;
    • Improve the Website, the App and the Services and develop new products, services, features, and functionality; and
    • Test the Website, the App and the Services and our infrastructure to make sure the Website, the App and the Services are working correctly.
  3. Marketing:
    As permitted by applicable law, we may use the Contact Information for marketing purposes, such as informing you about our products and services that could be useful, relevant, valuable, or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications.
4. How We Share Your Information
We may share, transfer, or disclose Contact Information, Account Information, Financial Information, Interest Survey Information, Voting Information, Third-Party Information, and Other Information (collectively, the “Information”) if you consent to us doing so, as well as in the following circumstances:
  1. To better understand and serve our customers.
    In an ongoing effort to better understand our users and our Website, the App and the Services, we might analyze your Information in aggregate form in order to operate, maintain, manage, and improve the Website, the App and the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
  2. To assist us running our business.
    We may employ other companies and individuals to perform certain business-related functions on our behalf. Examples may include providing marketing assistance, billing, payment processing, and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law. We may also share your Information with any of our parent companies, subsidiaries, affiliates, or other companies under common control with us.
  3. As part of the sale or other transfer of our business.
    As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of 6assets, dissolution, investment, or similar corporate event, your Information may be part of the transferred assets.
  4. For legal purposes.
    To the extent permitted by law, we may also disclose your Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of Troop or others.
  5. To serve Troop ’s community members.
    We will analyze your Information in anonymous and aggregate form and make it available to all Registered Users through the Services for the purpose of shareholder activism.
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.
5. SMS Text Messages
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, the App and/or ourServices 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 anytime 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.
6. Information Collected Through The Services That Is Not Covered By This Privacy Notice
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 USAND OTHER USERS OF THE SERVICES.
7. How We Protect Your Information
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, the App 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.
8. Children’s Information
We do not knowingly collect personal information from children under the age of 18 through the Website, the App 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.
9. External Websites
The Website, the App and the Services may contain links to third-party websites. Troop has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.
10. Accessing And Modifying Information And Communication Preferences
You may access, review, delete and make changes to your personal information by following the instructions found on our Website, App and the Services or by contacting us at info@troop.com. From time to time, we may offer features and functionality through the Services that will allow you to download the information we have collected about you.

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.
11. Do Not Track
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, the App 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.
12. Notice To Nevada Residents
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 info@troop.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.
13. Important Notice To Non-U.S. Residents
The Website, the App 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 UnitedStates 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, the App 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.
14. Updates To This Privacy Notice
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, the App and/or the Services after we notify you of changes to this Privacy Notice, you are deemed to have accepted such changes.
15. How To Contact Us
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  info@troop.com.