Last updated: November 11, 2026

This Privacy Policy explains how Egan-Jones Ratings Company ("Egan-Jones", "we", "us" or "our") collects, uses, shares and protects personal information. It applies to the websites we operate that link to this policy (each, a "Site"), our client platforms and portals, our credit ratings, research, proxy advisory and related services, and our communications and events (together, the "Services").

The policy covers visitors to our Sites, prospective and current clients and their authorized users, business contacts, job applicants, and people whose information appears in our ratings, research and reports. Where we handle personal information on behalf of a client, the client's agreement with us also governs that information.

1. Information we collect

Information you give us

Inquiries and requests. Your name, email address, company, job title, message and any other details you enter in a form or send to us.
Subscriptions. Your email address and the mailing lists or publications you sign up for.
Meetings and events. Contact details you give when booking a meeting or registering for an event, and notes of our conversations with you.
Client accounts. Names, job titles and business contact details of authorized users and other client contacts, their roles and permissions on our platforms, sign-in credentials, and billing contacts.
Information needed to deliver the Services. Information clients provide so that we can perform the Services, such as account details, holdings, instructions, and the names and contact details of people the client designates for reports or filings.
Communications. The content of emails, calls, meetings, support requests, feedback and comments. Calls and video meetings may be recorded or transcribed, with notice where the law requires it.
Job applications. Your resume, work history, education, references and anything else you include in an application. If you accept an offer of employment, we carry out a background check with your authorization and in line with the Fair Credit Reporting Act and other applicable laws.

Information we collect automatically

Device and usage information. Technical information such as your IP address, browser type, operating system, referring page, the pages you view and the date and time of your visit.
Platform activity. Sign-in times, actions taken in an account and related system logs, which we keep for security, audit and record-keeping.
Email engagement. Our emails may contain small images or tracked links that tell us whether a message was opened and which links were clicked.
Cookies and similar technologies. Described in our Cookies Policy.

Information from other sources

Our clients. Information a client gives us about its own staff, such as the people to give access to our platforms, and about the accounts and matters we handle for it.
Third parties involved in the Services. Data providers, custodians, intermediaries and other parties who supply information we need to perform the Services.
Business contact sources. Names, job titles, employers and business contact details from event organizers, professional networking sites, public sources and commercial data providers.
Public and research sources. Information about companies, issuers and the people who lead them, described in section 4.

2. How we use personal information

To provide, support and improve the Services.
To set up and manage client accounts, authenticate users and apply the permissions each client chooses.
To respond to inquiries, arrange meetings, provide support and send notices about the Services.
To send newsletters, commentary, event invitations and other information about our Services. You can unsubscribe at any time.
To consider job applicants and make hiring decisions.
To protect our Sites, platforms and systems, prevent fraud and misuse, and keep audit trails.
To manage conflicts of interest and maintain the information barriers described in section 5.
To understand how our Sites and Services are used, using aggregated or de-identified information where we can.
To keep records, meet our legal and regulatory obligations, respond to examinations and legal process, enforce our agreements and protect our legal rights.

We use artificial intelligence tools in parts of our work. We allow client information in an AI tool only where the provider's terms bar it from using that information to train its models.

3. How we share personal information

Service providers. Companies that host our Sites and platforms, store data, send email, provide scheduling, IT, security and support services, and provide professional services such as legal and accounting advice. They may use personal information only to provide their services to us.
Third parties involved in the Services. Custodians, intermediaries and other parties, as needed to carry out a client's instructions.
Our clients and report recipients. Information about a client's accounts and users goes to that client. Our ratings, research and reports, including the information described in section 4, go to the clients and other recipients they are prepared for.
Within Egan-Jones. Other parts of Egan-Jones that support our operations, such as compliance, technology and finance, subject to the information barriers in section 5.
Legal and regulatory. Regulators, courts, law enforcement and other authorities, when the law requires it or when we believe disclosure is needed to comply with legal process, respond to a regulatory examination, or protect the rights, property or safety of Egan-Jones, our clients or others.
Business transfers. A buyer, successor or other party, and their advisers, in connection with a merger, acquisition, financing or sale of all or part of our business.
With your consent or at your direction.

We do not sell personal information or share it for cross-context behavioral advertising, as those terms are defined under California law, and we do not give personal information to third parties for their own direct marketing.

4. People named in our ratings, research and reports

Our ratings, research and reports cover companies, issuers and the matters before their investors. To prepare them, we collect and analyze information about directors, officers, executives and other people named in public disclosures. This can include names, roles, biographies, tenure, board and committee memberships, compensation, share ownership and public statements.

We obtain this information from regulatory filings, company websites and announcements, stock exchange disclosures, news reports and licensed data providers. We use it to prepare and explain our analysis, because informed investment and voting decisions serve the legitimate interests of investors, the companies concerned and the wider market.

If you are named in our work and believe information about you is inaccurate, please contact us. We will review it and, if we confirm an error, correct it where needed.

5. Conflicts of interest and information barriers

We maintain policies, procedures and information barriers to manage conflicts of interest, including between our business lines. Information obtained in one part of our business is made available to another only where our policies allow.

6. Cookies and similar technologies

Our Sites use cookies and similar technologies that are needed to deliver them securely, and some Sites use optional analytics or embed third-party tools that may set their own cookies. Our Cookies Policy has the details and explains how to manage your choices.

Some browsers send Global Privacy Control or Do Not Track signals. Because we do not sell personal information or share it for cross-context behavioral advertising, these signals do not change how our Sites work.

7. How long we keep personal information

We keep personal information only for as long as we need it for the purposes described in this policy, including to provide the Services and to meet legal, regulatory, tax and accounting requirements. Our Data Retention Policy sets out the periods and criteria we apply.

8. How we protect personal information

We use administrative, technical and physical safeguards designed to protect personal information, including encryption of data in transit, access controls, limits on staff access to what each person needs for their work, and confidentiality obligations for staff and service providers. No system is completely secure, and we cannot guarantee the security of information sent over the internet. If a security incident affects your personal information, we will notify you and the relevant authorities where the law requires it.

9. Your choices

Marketing emails. Use the unsubscribe link in any marketing email, or contact us. We keep your email address on a suppression list so that we do not contact you again. You will still receive messages about Services you use.
Cookies. Use the cookie settings on a Site where offered, or your browser settings, as described in our Cookies Policy.
Account details. Authorized users can ask their organization's administrator, or us, to update their details.

10. Your privacy rights

Depending on where you live, you may have some or all of the following rights, subject to exceptions in the law:

to know what personal information we hold about you and how we use and share it, and to receive a copy;
to have inaccurate personal information corrected;
to have personal information deleted;
to receive personal information you gave us in a portable format;
to object to or restrict certain uses of your information, and to withdraw consent where we rely on it; and
to opt out of the sale of personal information, targeted advertising and certain profiling, none of which we carry out.

Making a request

Email compliance@egan-jones.com with "Privacy request" in the subject line, or write to us at the address in section 16. We will respond within the time the law allows, generally 45 days under US state privacy laws and one month under the GDPR, which may be extended in some cases. We will verify your identity before acting, usually by matching information you give us with information we already hold. You may use an authorized agent, in which case we may ask the agent for proof of authority and ask you to confirm your identity with us directly.

If your information is on one of our platforms because your organization is our client, we may refer your request to your organization and help it respond. We will not discriminate against you for exercising your rights.

Appeals

If we decline your request, you may appeal by replying to our decision or by emailing compliance@egan-jones.com with "Privacy appeal" in the subject line. We will respond in writing within the period the law requires. If you are not satisfied with the outcome, you may contact the attorney general of your state.

11. Additional information for California residents

This section supplements the rest of this policy for California residents and serves as our notice at collection under the California Consumer Privacy Act. In the past 12 months we have collected the categories of personal information below, from the sources described in section 1 and for the purposes described in section 2, and disclosed them for business purposes to the recipients listed.

Identifiers, such as name, email address, telephone number, postal address, IP address and account username. Disclosed to service providers, third parties involved in the Services, our clients (for their own users) and professional advisers.
Customer records described in California Civil Code section 1798.80(e), such as job title, employer, signature and account numbers. Disclosed to service providers, third parties involved in the Services and professional advisers.
Commercial information, such as the Services purchased, invoices and payment records. Disclosed to service providers and professional advisers.
Internet or other electronic network activity, such as pages viewed, email engagement and platform activity logs. Disclosed to service providers.
Audio or electronic information, such as recordings or transcripts of calls and meetings where we make them. Disclosed to service providers.
Professional or employment-related information, such as job titles and employers and, for job applicants, work history and background check results. Disclosed to service providers and professional advisers.
Education information included in job applications. Disclosed to service providers.
Sensitive personal information, limited to account sign-in credentials and, for job applicants who accept an offer, government identifiers and other information needed for a background check. Disclosed to service providers. We use it only for purposes permitted under California law, such as providing the Services, security and hiring, and not to infer characteristics about anyone.

We do not sell or share personal information, and we have no actual knowledge of selling or sharing the personal information of anyone under 16. We keep each category for the periods set out in our Data Retention Policy.

12. Additional information for individuals in the EEA, the UK and Switzerland

Egan-Jones Ratings Company is the controller of the personal information described in this policy, except where we process information on a client's behalf, in which case the client is the controller and we act as its processor. We rely on the following legal bases:

Contract, to provide the Services and manage client accounts.
Legitimate interests, to run and secure our business, to market our Services to business contacts, to prepare our ratings, research and reports, and to establish or defend legal claims. We weigh these interests against your rights and freedoms.
Legal obligation, to keep records and respond to regulators and courts.
Consent, where the law requires it, for example for optional cookies and certain marketing emails. You may withdraw consent at any time.

You may exercise the rights in section 10, including the right to object to processing based on legitimate interests and to object at any time to direct marketing. You may also complain to the data protection authority where you live or work.

We are based in the United States. We and our service providers process personal information in the United States and in other countries whose data protection laws may differ from those where you live. Where the law requires it, we protect these transfers with appropriate safeguards, such as the European Commission's Standard Contractual Clauses and their UK and Swiss equivalents. You may ask us for more information about these safeguards.

Our ratings, research and recommendations are prepared and reviewed by our analysts. We do not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

13. Children

Our Sites and Services are intended for business users and are not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has given us personal information, please contact us and we will delete it.

14. Links to other websites

Our Sites link to websites and services we do not control. Their own privacy policies govern how they handle your information.

15. Changes to this policy

We may update this policy from time to time. We will post the updated version and change the "Last updated" date. If we make material changes, we will take any further steps the law requires, such as notifying clients by email.

16. Contact us

Questions or requests about this policy or our privacy practices can be sent to:

Egan-Jones Ratings Company
Attn: Compliance
1120 Avenue of the Americas, 4th Floor
New York, NY 10036
Email: compliance@egan-jones.com

The reasoning behind every recommendation