Overseas Processing Statement
Some of our data processing occurs outside the country where the data originates. As a global organisation, Equiniti operates offices and processes data in multiple countries. We also work with third-party suppliers who may process data internationally. Currently, Equiniti processes data in the UK, the EEA, India, and the USA.
When personal data is transferred across international borders, we implement robust safeguards to ensure compliance with applicable data protection laws. This includes using data transfer agreements, standard contractual clauses (SCCs), and conducting Transfer Risk Assessments (TRAs).
Examples of international data transfers include:
- Sharing personal data with members of the Equiniti Group outside the UK, such as Equiniti India Private Limited, for purposes described in this Privacy Notice.
- When you contact us via email or use our microsites, some of our service providers may operate outside the UK.
Data Privacy Framework
For transfers to the US Equiniti complies with the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF, as set forth by the US Department of Commerce. Equiniti has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) and the UK Extension to the EU-US DPF, with regard to the processing of Personal Information received from the European Union and the United Kingdom in reliance on the EU-US DPF and the UK Extension to the EU-US DPF. If there is any conflict between the terms in this Privacy Statement and the EU-US DPF Principles and the UK Extension to the EU-US DPF, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
The legal entities of Equiniti that are adhering to the EU-U.S. DPF Principles, including as applicable under the UK Extension to the EU-U.S. DPF, and are covered by the Equiniti Trust Company, LLC DPF submission include: Amor Holdco, Inc., Armor Intermediate Company LLC, Armor Holding II LLC, Canadian Stock Transfer Holdings LLC, Equiniti (US) Holdings, LLC, Equiniti (US) LLC, DF King & Co, Inc, DF King Acquisition LLC, DF King Holding LLC, EQ Fund Solutions, LLC, LINK Shareholder Services, LLC and EQ Private Company Solutions, Inc.
In compliance with the EU-US DPF and the UK Extension to the EU-US DPF, Equiniti commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of Personal Information received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF.
Equiniti will arbitrate claims and follow the terms as set forth in the EU-U.S. DPF Principles and the UK Extension to the EU-US DPF, provided that an individual has invoked binding arbitration by delivering notice to Equiniti and following the procedures and subject to conditions set forth in Annex I of the EU-US DPF Principles and the UK Extension to the EU-US DPF. Under the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF Equiniti remains a liable party in cases of onward transfers to third parties if its supplier processes information in a manner that is inconsistent with the DPF principles, unless Equiniti proves that it is not responsible for the event giving rise to the damage. Equiniti is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC) regarding personal data received or transferred pursuant to DPF.
If you would like any further details about transfers of your personal data, then please contact our Data Protection Office at DPO@equiniti.com.