Last updated: November 10, 2026

This Privacy Policy explains how Egan-Jones Ratings Company ("Egan-Jones", "we", "us" or "our") collects, uses, shares and protects personal information in connection with Egan-Jones Proxy Services, the division through which Egan-Jones provides proxy services. It covers this website (the "Site"), the ProVote platform, our research, vote execution and Form N-PX reporting services, and related communications and events (together, the "Services").

The policy applies to visitors to the Site, prospective and current clients and their authorized users, business contacts, job applicants, and people whose information appears in our research, such as company directors and executives. Where we handle personal information on behalf of a client, such as holdings and voting data in ProVote, the client's agreement with us also governs that information.

1. Information we collect

Information you give us

Messages and demo requests. Your name, email address, company, your message and the page you sent it from.
Newsletter sign-ups. Your email address and the mailing lists you join.
Meeting bookings. Your name, email address, the time you choose and your answers to any booking questions, such as your company.
Events. Business contact details and notes of our conversation when you meet us at a conference or other event.
Client accounts. Names, job titles, business email addresses and telephone numbers of authorized users and other client contacts, their roles and permissions in ProVote, sign-in credentials, and billing contacts.
Information needed to deliver the Services. Holdings lists, custodian account names and numbers, ballots, the voting policies selected, voting instructions and overrides, vote records, and the details needed for Form N-PX reports, such as the names and contact details of a client's filing contacts and signatories.
Communications. The content of emails, calls, meetings, support requests, feedback and error reports. 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. When you visit the Site, our hosting providers record 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.
ProVote activity. Sign-in times, actions taken in an account, such as reports viewed, overrides selected and votes submitted, and related system logs, which we keep for security, audit and client 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. A limited set, 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 invite to ProVote, and about the accounts it manages.
Custodians and proxy voting intermediaries. Ballots, meeting materials, account identifiers and vote confirmations from custodians, proxy distribution and vote-execution networks, and vote tabulators.
Business contact sources. Names, job titles, employers and business contact details of potential clients from conference and event organizers, professional networking sites, public sources and commercial data providers.
Research sources. Information about public companies and the people who lead them, described in section 4.

2. How we use personal information

To provide the Services: publishing research reports, applying the voting policies our clients select, submitting and confirming votes, and preparing Form N-PX reports.
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, such as report notifications and changes to our terms.
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 the Site, ProVote and our 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 the Site and the Services are used and to improve them, using aggregated or de-identified information where we can.
To keep records, respond to regulatory 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 the Site and ProVote, store data, send email, run our scheduling tool, and provide IT, security, support and professional services such as legal and accounting advice. They may use personal information only to provide their services to us.
Proxy voting intermediaries. Custodians, proxy distribution and vote-execution networks, tabulators and companies' agents, as needed to receive ballots, cast votes on our clients' instructions and confirm those votes.
Our clients and research recipients. Information about a client's accounts and users goes to that client's administrators. Research reports, including the information described in section 4, go to our clients and to other businesses that buy our research, and a company may receive a copy of the report about it.
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. For example, when a client asks us to send its vote records to its auditors.

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. Directors, executives and others named in our research

Our research reports and vote recommendations cover public companies and the matters on their shareholder meeting agendas. To prepare them, we collect and analyze information about directors, director nominees, executives, shareholder proponents and other people named in proxy materials. This can include names, ages, roles, biographies, tenure, board and committee memberships, other directorships, meeting attendance, compensation, share ownership, past voting results and public statements.

We obtain this information from company filings with the SEC and other regulators, company websites and announcements, stock exchange disclosures, news reports and licensed financial data providers. We use it to assess the matters before shareholders under the voting policies our clients select and to explain our recommendations. We process it because informed shareholder voting serves the legitimate interests of investors, the companies concerned and the wider market.

If you are named in our research and believe information about you is inaccurate, please contact us. We will review it under our correction process and, if we confirm an error, publish a corrected report where needed.

5. Information barriers between proxy services and credit ratings

Egan-Jones also issues credit ratings. Egan-Jones Proxy Services is kept physically and electronically separate from the credit ratings business so that information about proxy clients' holdings, votes and voting recommendations cannot influence ratings activities. That information is not made available to the people who determine credit ratings, and proxy staff do not have access to the ratings business's list of rated companies.

6. Cookies and similar technologies

The Site uses cookies and similar technologies needed to deliver it securely, and our scheduling provider may set its own cookies when the booking window loads. Apart from the scheduler, the Site does not use analytics or advertising cookies. Our Cookies Policy has the details, including how to manage cookies in your browser.

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 the Site works.

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, to support our clients' record-keeping and to meet legal, regulatory, tax and accounting requirements. Our Data Retention Policy sets out the periods and criteria we apply to each type of record.

8. How we protect personal information

We use administrative, technical and physical safeguards designed to protect personal information. These include encryption of data in transit, role-based access controls in ProVote, limits on staff access to what each person needs for their work, confidentiality obligations for staff and service providers, and the information barriers described in section 5. 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, such as report notifications.
Cookies. You can block or delete cookies in your browser settings, although parts of the Site, such as the scheduler, may not work without them.
Account details. Authorized users can ask their organization's ProVote 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 in ProVote because your organization is our client, we may refer your request to your organization, which controls that information, 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, proxy voting intermediaries, 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 custodian account numbers. Disclosed to service providers, proxy voting intermediaries 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 ProVote 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. We do not disclose personal information to third parties for their own direct marketing purposes.

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 research about public companies and the people who lead them, 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 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 recommendations are prepared by analysts applying written voting policies, and every report is reviewed by a second analyst or a supervisor before publication. We do not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

13. Children

The Site and the 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

The Site links to websites and services we do not control, such as social media sites and our scheduling provider. 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 on this page 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, Egan-Jones Proxy Services
1120 Avenue of the Americas, 4th Floor
New York, NY 10036
Email: compliance@egan-jones.com
Phone: (646) 883-9898

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